SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 1 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

### APPENDIX C

2006 FINAL STAFF REPORT SUBMITTED WITH FOR RULE 4570 (CONFINED ANIMAL FACILITIES)

June 18, 2009SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 2 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 3 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT

RULE 4570 (CONFINED ANIMAL FACILITIES)

June 15, 2006

Prepared by: Lucinda Roth, Air Quality Specialist Alvin Valeriano, Senior Air Quality Specialist

Reviewed by: Maria Stobbe, Planning Manager George Heinen, Supervising Air Quality Engineer Joven R. Nazareno, Seni or Air Quality Engineer David Warner, Director of Permit Services Sheraz Gill, Senior Air Quality Engineer Richard Karrs, Senior Air Quality Engineer Steve Brodie, Air Quality Inspector

I. SUMMARY

A. Reasons for Rule Development and Implementation

In terms of state and federal standards, the California Ai r Resources Board (ARB) and United States Environmental Protection Agen cy (EPA) classified the San Joaquin Valley Air Basin (SJVAB) as a non-attainment area fo r ozone. The District is classified as a

serious non-attainment area for the federal 8-hour ozone National Ambient Air Quality Standards (NAAQS). It is antic ipated that attainment of the eight-hour standard will require the control measures cited in the one-hour Extreme Ozone Attainment Plan (Ozone Plan), which include control measure 4570 (Confined Animal Facilities). Since Proposed Rule 4570 is a control measure in t he District’s Ozone Plan, it is subject to Federal Register, Clean Air Act (CAA), and Ca lifornia Health and Safety Code (CH&SC) requirements. Additionally, anti-backsliding provisions commi t the District to develop all

control measures listed in the Ozone Plan (Federal Register Volumes 69 and 70). These requirements are summarized in Table 1.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 4 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Table 1 Anti-backsliding and Ozone Plan Commitments Subject Reference Requirement

Antibacksliding 69 Federal Register

23955 Districts shall develop all control measures

listed in the one-hour Ozone Plan until the District is designated as attainment for the 8-
hr NAAQS.

BACM Federal Register

8/18/94 Provisions in attainment plans should include the application of best available control measures (BACM) to existing major stationary

sources.

BARCT CH&SC 40919(a)(3)

Ozone Plan Ozone attainment plans should provide for best available retrofit technology (BARCT) for existing permitted sources.

BARCT is specifically required for "large"

Confined Animal Facilities (CAF).

Deadlines Ozone Plan Rule adopti on by the 2nd quarter of 2006.

Feasible

Controls CH&SC 40914(a)(2) Ozone attainment plans should include "all

feasible control measures."

RACT CAA 182(b)(2) and 182(f) Ozone attainment plans shall assure that reasonable available control technology (RACT) for volatile organic compounds (VOC) is in use at sources and on source categories

at or above the RACT threshold.

RACT

Threshold 70 Federal Register

30592-30596 The applicable RACT threshold for control

measures shall be the threshold in effect on June 15, 2004. The Districts threshold on June 15, 2004 was 10 tons per year (tpy) for VOC. Therefore, 10 tpy is the RACT threshold for Proposed Rule 4570.

Reductions Ozone Plan The rule shall reduce VOC emissions by atleast 25% from the baseline by 2010. Twentyfive percent of the baseline used for the Ozone Plan (63.1 tpd) is 15.8 tpd.

Timeline CAA Section 172(c)(1) Ozone attainment plans shall implement control measures as expeditiously as practicable, and provide for attainment.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 5 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Proposed Rule 4570 is also intended to fulfill the following CH&SC requirements created by the passage of Califor nia’s Senate Bill 700 (SB 700):

Table 2 SB700/California Health and Safety Code Requirements
Subject CH&SC Sections SB700 / CH&SC Requirements Large Confined Animal Facility Definition (large CAF) 40724.6(a) The District shall use the "large CAF" definition developed by the California Air Resources Board (ARB).

Deadline 40724.6(b) By July 1, 2006 the District shall adopt, implement, and submit for inclusion in the state implementation plan a rule requiring owners of "large" CAF to obtain a permit. Degree of Mitigation Required 40724.6(d)(1)(B) Best Available Retrofit Control Technology (BARCT) is the degree of mitigation required of large CAF.

Compliance Schedule 40724.6(d)(4) Owner/operators shall implement control measures

within one year of the permit issuance date.

Permit Requirements to

be Included in the Rule 40724.6(d) 1. The permit shall include an emission mitigation plan that demonstrates use of BARCT, (Rule 4570 Section 5.0) 2. The District shall provide for a 30-day public noticing and commenting period for proposed permits, (Rule 4570 Section 6.1.6) 3. The District shall review and update permits at least once every three (3) years, (Rule 4570 Section 6.2) 4. The District shall act on completed permit applications within six (6) months of receipt, (Rule 4570 Section 6.3) 5. The permit shall include sufficient information to prepare an emission inventory of all regulated air pollutants emitted from the facility, and (Rule 4570 Sections 6.0 and 7.0) 6. The owner/operators of large CAF shall submit a permit application within six (6) months of Rule 4570 adoption. (Rule 4570 Section 8.1)

Impact Assessment 40724.6(d) Prior to adopting a rule, the District shall analyze the following: 1. Category, number, and size of facilities affected, (Section II of the Staff Report) 2. Nature, quantity, and significance of emissions in adversely affecting public health, the environment, and attainment of air quality standards, (Section IB and Section II of the Staff Report) 3. Emission reduction potential, (Appendix B) 4. Costs, (Appendix C and D) 5. Impact on employment and the economy, (Appendix D) 6. Alternative controls, and (Section III of the Staff Report) 7. Technical and Practical Feasibility. (Section III of the Staff Report)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 6 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 B. Scope of Proposed Rule 4570

Rule 4570 is properly limited to VOC r egulation. Proposed Rule 4570 was developed pursuant to California Health and Safety Code (CH&SC) 40724.6, which applies only to the regulation of ozone and oz one precursors. This is confirmed by CH&SC 40724.6(d)(1)(B), which requires, amongst other things, the implementation of reasonably available control technology (RACT) in "moderate" and "serious" nonattainment areas, and best available retrofit control technology (BARCT) in "severe"

and "extreme" nonattainment areas. "Severe" and "extreme", as used in these sections of the CH&SC, are legal terms that pertain only to ozone attainment status. Please see CH&SC 40724.6(d)(1)(B) for additional inform ation. Due to the fact that the aforementioned sections only apply to ozone and ozone precursors, controlling

emissions of other non-ozone re lated pollutants, such as a mmonia, is not mandated or permitted.

Pursuant to CH&SC 40724.6(d)(4)(d)(2), t he District analyzed the significance of

emissions from CAFs and determined that t he rule should focus on the control of volatile organic compounds (“VOC s”) as ozone precursors.

Ammonia is not being targeted by this rule because ammonia is a particulate matter precursor and not an ozone precursor. So me commenters inaccurately stated that Proposed Rule 4570 must regulate ammo nia because CH&SC 40724(a) requires BARCT controls for particulate matter (PM) precursors, and ammonia is a precursor for both PM10 and PM2.5. The District disagrees with this comment for several reasons. First, as discussed above, Rule 4570 is being adopted pursuant to CH&SC 40724.6, which authorizes the regulation of ozone, not particulate matter. The District complied with CH&SC 40724(a) when it adopted its Rule 4550 (Conservation Management Practices) in May and August 200 4. To the extent that the commenters believe that ammonia should have been regulated under that rule, their comments are misplaced in this rule development process, as this is a separate district rulemaking activity. However, in an effort to respond to these comments, the District offers the following: Ammonia was not targeted by Rule 4550 bec ause, based on the District's PM-10 Plan; the preliminary results from the California Regional PM 10/PM2.5 Air Quality Study (CRPAQS); and the Ninth Circuit decision in Association of Irritat ed Residents vs. U.S. Environmental Protection Agency , 423 F.3d 989 (9 th Circuit 2005), reducing ammonia is not an effective method of achieving attain ment for particulate matter. Oxides of nitrogen (NOx), not ammonia, ar e the limiting reagents in the fo rmation of PM in the San Joaquin Valley. The District could reduce over half of the ammonia from CAFs and not affect particulate matter formation. Fu rthermore, CH&SC 40724(a) requires the District to regulate PM precursors "in a manner co mmensurate to other so urce categories." Since current District rules do not require any other source category to control ammonia, this rule cannot do so for confined animal facilities. In addition, the District did not regulate PM2.5 in Rule 4550 bec ause CH&SC 40724(a) applies only to the regulation of PM in federal nonattainment areas designated as nonattainment for PM2.5 as of January 1, 2004. The San Joaquin Va lley was not designated as nonattainmentSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 7 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 for PM2.5 until April 5, 2005, well after the January 2004 applicability date. Thus, CH&SC 40724(a) does not require regulation of PM 2.5 precursors in the San Joaquin Valley.

Returning to the rule at issue here, Proposed Ru le 4570, even if the District agreed that CH&SC 40724.6 applied to all "air cont aminants" as commenters suggest, CH&SC 40724.6(b) requires that emissions from a facility be reduced "to the extent feasible." In

order to be "feasible" emission reductions mu st have some relationship to the pollution problem being addressed. Since Proposed Ru le 4570 seeks to reduce ozone pollution, it would be nonsensical to attempt to cont rol ammonia, soot, odor, or other "air

contaminants" that have no effect on ozone leve ls in the San Joaquin Valley. Such a regulation would not survive the requir ed socioeconomic analysi s because the money spent on controls would not result in an impr ovement in ozone levels in the San Joaquin Valley. Therefore, such controls would not be considered "feasible."

In addition, the District is prohibited from r equiring controls in Proposed Rule 4570 that would duplicate controls required for parti culate matter in Rule 4550. CH&SC 40724.6(h) states that " nothing in this section authorizes a district to adopt a rule or regulation that is duplicative of a rule or regulation adopted pursuant to CH&SC 40724 and 40724.5." As discussed above, Rule 455 0 (Conservation Management Practices) was adopted pursuant to CH&SC 40724. Rule 4550 contains the required PM controls for agricultural sources, including confined ani mal facilities. As a result, the present ozone rule, Proposed Rule 4570, could not sim ilarly regulate particulate matter pollution as that would be "duplicative" and thus in violation of CH&SC 40724.6(h).

Finally, CH&SC 40724.6(d)(4)(d) states that the District must consider the impacts of a rule adopted under the aforementioned sectio n and assess, amongst other things, "the nature and quantity of em issions from the category and the significance of those emissions in ... causing or contributing to the violation of a state or federal ambient air quality standard." As discussed above, the District performed this analysis for ammonia when it adopted it PM10 Plan in 2003 and again when it adopted an update to that Plan in 2006. This analysis determined that contro lling ammonia is not an effective strategy for reducing particulate matter in the Valley. This analysis was affirmed by the Ninth

Circuit in Association of Irritated Residents vs. U.S. Environmental Protection Agency. However, even though the District is not required to regulate ammonia with this rule, it is important to note that many of the mitigation measures required by the rule to reduce VOCs also reduce ammonia. As a result, th is rule is expected to reduce ammonia from large CAFs by over 30%, as demonstrated in Appendix F.

The District also analyzed NOx pursuant to CH&SC 40724.6(d)(4)(d) . Although NOx is an ozone and particulate matter precursor, Rule 4570 does no t require NOx controls at

CAFs. This is because animals and m anure emit minimal quant ities of NOx. Furthermore, the scope of this rule is limited to animal husbandry including manure disposal, not engines on these facilities. However, the District implemented BARCT for NOx emissions on CAFs from engines, boilers, and other sources in other District RulesSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 8 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 including, but not limited to, District Rules 4301, 4304 through 4308, and 4701 through

4703.

Accordingly, because Rule 4570 as a measur e for the District’s Ozone Plan pursuant the authority set forth in H &SC section 40724.6, which aut horizes the regulation of ozone and ozone precursors, this rule focuses on the regulation of VOCs, which are the pollutants that contribute to the Distr ict’s non-attainment status for ozone.

C. Large CAF Definition

A CAF is defined in CH&SC 39011.5(a) and 39011. 5(a)(1). Based on these sections of the CH&SC, a CAF is "a source of air po llution or a group of sources used in the...raising of fowl or animals located on contiguous property under common ownership or control...including, but not limited to, any st ructure, building, inst allation, barn, corral, coop, feed storage area, milking parlor, or system for the co llection, storage, treatment, and distribution of liquid and solid manure, if domesticated animals are corralled, penned, or otherwise caused to remain in rest ricted areas for comm ercial purposes and feeding is by means other than grazing."

The California Air Resources Board (ARB ) was required by CH&SC 40724.6 to "review all available scientific information, includi ng, but not limited to, emission factors for confined animal facilities; the effect of t hose facilities on air quality in the basin; and

other relevant scientific information and to develop a definition for a "large" confined animal facility. ARB's board adopted the follo wing thresholds for a large CAF, based on

air emissions from CAFs:

Table 3: ARB Large CAF Thresholds Livestock Category Number of Animals Dairy 1,000 lactating cows

Beef Feedlots 3,500 beef cattle Other Cattle Operations 7,500 calves, heifers, and other cattle Chickens-Broilers & Egg Layers 650,000 head Turkeys 100,000 head

Swine 3,000 head Sheep and Goats 15,000 head

Horses 2,500 head

Ducks 650,000 head Other Livestock Not Previously Mentioned 30,000 head Source: http://www.arb.ca.gov/regact/l caf05/lcaf05.htm accessed 2/24/06

D. Permits Requirements

CH&SC 40724.6(c) provides the District with t he authority to require permits on facilities with less than one half of any applicable emissi ons threshold, if they make certain findings, as quoted below:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 9 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 "A district may require a permit for a large confined an imal facility with actual

emissions that are less than one-half of any applicable emissions threshold for a major source in the distri ct for any air contaminant, including, but not limited to, fugitive emissions in a manner similar to ot her source categories if, prior to imposing that requirement, the distri ct makes both of the followi ng determinations in a public hearing:

(1) A permit is necessary to impose or enforce reductions in emissions of air pollutants that the district show cause or contribute to a viol ation of a state or

federal ambient air quality standard and

(2) The requirement for a sour ce or category of sources to obtain a permit would not impose a burden on those sources that is significantly more burdensome than permits required for other similar sources of air pollution." (CH&SC 40724.6)

Staff believes that without a permit, deter mining compliance with Proposed Rule 4570 and ensuring compliance would not be feasible. A permit is the legal document through which we enforce the rule for permitted s ources. Furthermore, since many of the affected sources already have permits and this rule would only require a modification to their existing permits, staff does not believe the permit requirement in Proposed Rule 4570 would impose a burden. The District will make these findings at a public hearing on June 15, 2006.

E. RACT Requirements

Reasonably Available Control Technology (R ACT) is required by CAA 182(b)(2) and 182(f) for any facility with at least ten (10) to ns per year (tpy) of VOC emissions. The

emissions factors for confined animal facilitie s are being revised; therefore, it is not possible to conclusively identify the number of animals of any species that would trigger RACT requirements. The development of this ru le cannot be postponed until

finalization of the emission factor due to the CH&SC 40 724.6 requirements for rule adoption by July 1, 2006. Preliminary discu ssion with EPA staff suggest that, due to the current uncertainty of the emi ssion factors, at this time EPA will consider the RACT and large CAF thresholds to be equivalent. T herefore, staf f will address those facilities defined as "large CAF" by the ARB in Pr oposed Rule 4570 to be adopted on or before July 1, 2006. Later, after emission factors ar e more refined, staff may amend this rule to address CAFs below the large CAF definit ion, but at or abov e the ten (10) tpy emission threshold for RACT, if it is determined that such sources exist.

F. Scientific Background Review/Revision

Due to the relatively new status of CAFs as a regulated stationary source, the body of scientific knowledge that is useful in underst anding its impact on air pollution is not as well established compared to other traditional stationary sources under the jurisdictionSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 10 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 of the District. New scientific findings char acterizing and quantifying dairy, poultry, and other animal emissions and possible cont rol measures are being developed and completed. The District developed Proposed Rule 4570 using relevant findings from previous research efforts as they were finalized, published, and peer-reviewed. These include, but are not limited to:

• A study at UC Davis, led by Dr. Fr ank Mitloehner, which focused on emissions

from cows housed in environmental c hambers to evaluate the emissions produced directly from cows and their fresh manure.

• A study at two operating dairies in t he San Joaquin Valley, led by Dr. Chuck Schmidt, in which measurements were made at various locations at the dairies, including the corrals and turnouts, bedding areas, lagoons, feed storage areas, flush lanes, and bunker feed.

• A study by Dr. Schmidt to validate t he effectiveness and capture efficiency of using flux chambers that were used to quantify emissions in the dairy studies.

These studies have provided significant fi ndings that provide an understanding of the

emissions at CAFs. Due to the rule adoption date mandated by CH&SC 40724.6 and the presence of peer-reviewed and preliminar y research data, st aff will propose rule adoption no later than July 1, 2006.

Since control efficiencies for technolog ies and emission factors may change based on new research, staff structured the rule su ch that facilities may comply with rule requirements utilizing management practice s and machinery that owners/operators already have access to onsite. This is intended to implement BARCT, while preventing owners/operators from bei ng required to invest significant capital in a technology that is later found to control only a small portion of the emissions. Staff may amend this rule after July 1, 2006 when additional research is completed, which may require owners/operators to make c apital investment beyond the mi tigation measures currently being proposed in Rule 4570. At that time, the emission s from each area would be better quantified, and staff would be able to determine which VOC emission mitigation measures have the highest cost effectiveness values.

Since testing methods are being developed, sta ff left the testing requirements flexible to prevent owners/operators fr om being required to invest signi ficant capital in testing that

is later found to be ineffective or not the mo st cost effective met hod. Furthermore, the rule provides the flexibility for the APCO, ARB, and EPA to add additional test method options that they believe are appropriate. Th is concept acknowledges that, as research continues, new, more effective, and less ex pensive test methods may be developed and, if so, owner/operators should be allowed to use such methods.

While the studies by Dr. Schmidt and Dr . Mitloehner have provided valuable new information, they do not fully address air emi ssions from CAF. Additional work is needed to allow a comprehensive update to the emission factors currently being used

for CAF. As additional resear ch, such as that being under taken by the California AirSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 11 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Resources Board, becomes finalized, this ru le may be adjusted to incorporate that new information. Please see Appendix H for additional information on ongoing studies.

II. BACKGROUND

CAF are used for the raising of animals incl uding, but not limited to, cattle, calves, chickens, ducks, goats, horses, sheep, swine, rabbits, and turkeys, which are corralled, penned, or otherwise caused to remain in rest ricted areas for comm ercial agricultural purposes and fed by a means other than grazing. (CH&SC 39011.5 (a)(1))

Due to the different methods of conf inement and associated manure management, there is no typical CAF. The design and ope ration of a CAF varies depending on animal type, regional climatic conditions, busi ness practices, and preferences of the owners/operators. This is why Proposed Rule 4570 provides a menu of options for the owners/operators. This ack nowledges that not all faciliti es can implement the same options due to infrastructure, conditional use permits, water board permits, soil types, production contracts, and other limitations. It also enables the people that understand the particular operation best, t he owners/operators, to choose the mitigation measures

that make the best environmental and economic sense for the facility.

A. General Description of Poultry Operations

Poultry facilities operate either as layer r anches 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, ma y 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.

This typical practice of having no more than 650,000 birds on a single property or contiguous properties is for biosecurity pur poses. Although the farms that make up a ranch may be operated as a si ngle facility all using the same equipment, personnel, and operators and having a single owner , if the farms are not on c ontiguous properties they will each be considered a separate agricultu ral source based on the definition of a single agricultural source in CH&SC Sectio ns 39011.5(a) and 39011.5(a )(1). Therefore, the majority of the existing poultry operations are expected to be below the thresholds established for control requirements.

In the United States, approxim ately 61% of the chicken layer houses and a majority of the breeder and broiler houses use power ventila tion 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.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 12 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Studies indicate that most chicken layer houses produce approximately two cubic yards of waste per week per five hundred chick ens. Although a small amount of liquid waste may occur from egg washing operations loca ted on the facility and a small amount of bedding may be collected as waste, poultry excr etions account for a majority of the waste. Typically, hens are confined in a la yer house that consists of many layer boxes positioned above the ground. On average, ev ery seven (7) to nine (9) days workers remove waste from under the layer boxes , and every fourteen (14) to eighteen (18)

weeks workers remove waste from the fl oor of the layer houses. However, many facilities list less frequent waste removal, r anging from one (1) to three (3) times per year (every 17-52 weeks) as a control tec hnique used to comply with District Rule 4550 Conservation Management Plan (CMP). Severa l mitigation measures in Proposed Rule

4570 and Rule 4550 that the owners/operators could choose do not affect waste removal frequency. Therefore, owners/oper ators can comply with both Rule 4550 and

4570.

In broiler facilities, comple te litter removal from the hous e occurs one (1) to four (4) times per year. Litter removal frequencies vary from every two (2) to seven (7) flocks (approximately 90-315 days); more commonly, it is removed ev ery third flock. Before introducing a new flock, the house is left empty, typically for five (5 ) days. During this interlude, the operator adjusts the temperature and other am bient conditions in the house. In the broiler industry, the new flocks of birds are brought into the houses as chicks and are raised for approximately 45 days, until they reach the desired weight. Shortly thereafter, the grow n birds are removed and the house is again left empty for approximately five (5) 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 liv e bird weight. On average, for each pound of live weight gained, meat birds produced 0.52 pou nds of litter during the production period.

Poultry excretions and bedding materials, such as rice hulls, are removed either by scraping or by flushing. In a scrape system, the litter is eit her 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, explained later in this report. However, less than 15% of the poultry operations in the San Joaquin Valley use liquid manur e handling systems.

Based on current preliminary research data, litter and feed are the major sources of VOC emissions. These emission points are also sources of ammonia emissions. Since ammonia forms a significant health risk to t he animals and decreases productivity, many facilities implement controls for ammonia. The humidity, litter additive, moisture, and ventilation controls widely used to contro l ammonia also constitute BARCT for VOC emissions. Based on industry comments, sta ff believes that the majority of poultry facilities in the SJVAB already implement BA RCT for VOC emissions. Furthermore, theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 13 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 studies conducted to determine emissions fa ctors for poultry we re on poultry houses that had implemented BARCT, t hus the baseline for poultry emissions includes BARCT.

B. Dairy Operations

For this description, dairy operations are def ined as those operations producing milk or animals for facilities that produce milk. In or der to produce milk, the cows must be bred and give birth. Typically, the gestation per iod for dairy cattle is nine (9) months and dairy cows are bred again approximately four (4) months after calving. Milk production typically peaks shortly after calving and then declines. Commonl y a cow will produce milk for ten (10) to twelve (12) months and then be dry approximately two (2) months. Thus, a dairy operation may have several types of animal groups present including heifers, lactating cows, dry cows, calv es, and bulls (for breeding purposes). Approximately 25% of a milking herd is r eplaced each year, but r eplacement 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 predominate 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 sta lls for resting. Standard freestall barns have a feed alley in the cent er of the barn separating two feed bunks on each side.

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 c onfined in or have access to drylots. Drylots are typically fenced in ar eas that may have shade. Drylot confinements

are similar to beef feedlots described later in this report. Tie stalls/stanchions are not uncommon on smaller dairy farms and older facilit ies. 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 cl eaned 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 (4) to five (5) days after birt h. Calves are then f ed a milk replacement until weaning, which generally occurs at abo ut eight (8) weeks of age. During this period, a feed grain based starte r diet is introduced. This st arter diet is fed to calves until they are approximately thre e (3) months old. At appr oximately three (3) months, calf rumen development allows a shift to a roughage-based diet.

Older cattle and calves being raised for m ilk production are commonly fed a roughagebased diet. The principal constituents of t hese diets are corn or grain sorghum silage and legume or grass and legume hays with f eed grains and byproduct foodstuff added in varying amounts to satisfy energy, protei n, and other nutrient requirements. The manure tends to be generated in a semi-solid state.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 14 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Manure with a total solid content of 10% or le ss can be handled as a liquid. In slurry or liquid systems, the manure is flus hed from alleys or pits to a st orage facility. Typically, effluent from the solid separation system or supernatant from a pond or an anaerobic lagoon is used as flush water in animal housi ng. The supernatant is the clear liquid in the lagoon that is overlying the solids that settle below. Da iry manure that is handled and stored as a slurry or liquid may be mi xed 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 solid s can be removed by mechanized scraping systems, a tractor, or a chain scraper. Typi cally, the solid manure scraped is stock piled and dried for disposal through land application.

C. General Description for Beef Cattle Feeding Operations

This animal sector includes adult beef cattle (heifers and steers). Beef may spend all, part, or none of their lives on a CAF. There are three types of oper ations in the beef industry: cow-calf operations, backgroundi ng operations, and finishing operations. These operations are typically conducted at s eparate 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 slau ghter. These animals are fed primarily hay with some grain and ot her foodstuff. Backgrounding or stocker operations prepare weaned calves for finishi ng. 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 t he backgrounding process may be from thirty (30) days to six (6) months old. Typicall y, high grain prices favor longer periods of backgrounding by reducing feed costs for finish ing or fattening. Af ter approximately 150 to180 days, animals in finishing operations will reach slaughter we ights of 1,050 to 1,250 pounds. Although, some feedlots star t 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 segr egated by production st age in pens with feed truck access. The animals are typically fed two (2) to three (3) ti mes per day using feed bunks located along feed alleys that separate the individual pens.

For these types of operations, the manur e is commonly handled as a solid. Solid manure is typically scraped or moved by tracto rs to stockpiles. Manure accumulates in areas around feed bunks and water troughs most r apidly, thus these areas may need to be cleaned during the finisher cycle. Howeve r, there is signific ant concern and risks

associated with enter ing areas where beef cattle are housed.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 15 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 D. General Description for Swine Operations

The production cycle for hogs has three (3) phas es: farrowing, nursing, and finishing. The first phase begins with breeding and gesta tion over a 114-day period followed by farrowing (giving birth). After farrowing, t he newly born pigs or piglets normally are nursed for a period of three (3) to four (4) weeks until they reach a weight of approximately ten (10) to fi fteen (15) pounds. Typically, t here are from nine (9) to eleven (11) pigs per litter. Sows can be bred again within a week after a litter is weaned. Sows normally produce five (5) to six (6) litters before they are sold for slaughter at a weight of 400 to 460 pounds.

Weaned pigs are fed a starter ra tion until they reach a weight of approximately fifty (50) to sixty (60) pounds. At this poi nt, they are typically eight (8 ) to ten (10) weeks of age. Then the animals are fed a growing and fina lly 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 confi nement buildings that are either totally enclosed or open-sided with curtains. Tota lly enclosed facilities are mechanically ventilated throughout the year . Open-sided buildings are naturally ventilated the majority of the year, but may be mechanicall y ventilated when the curtains are closed due to weather conditions. Manure may be flus hed from the floor of the housing or fall through slats in the floor to a pit underneath t he floor. Manure in the pit may be flushed or scraped.

E. Land Application of Animal Waste

Liquid manure from flush systems stored in lagoons or solid manure scraped from facilities eventually may be land applied wit h or without prior treatment such as composting or anaerobic digestion. Typically , animal waste is applied to cropland at rates adequate to supply crop nutrient needs. Historically the determination of application rates has been based on crop ni trogen requirements due to concern about the impact of excess nitrogen on surface and gr ound water. In cases where treatment methods, such as aerobic digestion, increase the nitrogen content in the waste stream, the waste may need to be applied over a greater number of acres in order to comply with the Regional Water Qua lity Board’s regulations.

Surface application of manure waste may be done with a spreading device known as a box manure spreader. This is simply a rectangul ar box that is eit her tractor drawn or truck mounted with a spreading device at t he rear end. During sp reading, the manure moves to the rear of the box by either a bel t or chain-and flight conveyor. Box type spreaders are typically loaded with tractor mounted front-end loaders . Manure handled as slurry or liquid may be spread with a trac tor drawn or truck mounted tank known as a liquid manure spreader. The manure may be forced out of the tank under pressureSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 16 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 against a distribution plate to create a spray pattern. Another option is to force the

manure from the tank under pressure through a manifold with a series of hanging or trailing pipes to create parallel strips of manure on the soil surface. A second type of spreader for manure slurries is a flail spreader. This is a partially open tank with chains attached to a rotating shaft positioned parallel to the direction of travel. Manure is discharged perpendicular to the direction of travel by the momentum transferred from rotating chains.

Manure may be land applied and land incorp orated through the use of a manure injection device, typically attached to a tr actor; tilling surface applied manure under the soil; applying liquid manure at such a rate that is rapidly absorbed into the soil; or

another method in which the manure is covered with soil.

Facilities choosing to use conservation tillage options will likely apply any liquid manure at a rate such that it is rapidly absor bed into the soil and apply any solid manure only

after it has been treated with an anaerobic di gestion process, treated with an aerobic digestion process, or dried to a moisture content of le ss than 50%. In any of these cases the animal waste land applied would not need to be tilled under the soil in order to comply with rule requirements. Simila rly, such methods may be used when crop height prevents the owner /operator from tilling the land-applied waste.

F. Emission Characterization

Current research suggests that general s ources of VOC on CAF may include: enteric (i.e. eructation and respiration), bedding, ex creta, and feed. (Schmidt, 2004) In excreta, the majority of the non-methane volatile organic compounds (NMVOC) originate from the decomposit ion of undigested protein (Hobbs 2004). Sources of VOC from excreta include animal housing, yard s, manure storage areas , land spreading, solid separator piles, and lagoons.

The District extensively reviewed current re search in the APCO reports available at: http://www.valleyair.org/ busind/pto/dpag/dpag_idx.htm

The District identified the following emission categories:

• Category 1- Feed and Enteric from an Environmental Chamber: Several VOC including aromatics and ethanol were not measured. Ethanol was the main VOC found in feed in Dr. Chuck Schmidt's study;

• Category 2- Ethylamines from Specific Dairy Processes: Does not include emissions from several processes, incl uding feed storage, l and application, and composting;SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 17 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 • Category 3- VOC from Miscellaneous Da iry Processes: Several VOC including

methanol were not measured and several important processes including feed storage, land application, and co mposting were not included;

• Category 4- VOC from Lagoons and St orage Ponds: Several VOC including

aromatics and ethanol we re not measured;

• Category 5- Volatile Fatty Acids: Used low range estimates and minimums for

several VFA calculations so it ma y underestimate the VFAs at dairies;

• Category 6- Phenols from Dairy Processe s: Not included because no information regarding the relationship between pheno l formation and diet and process conditions was provided to the APCO; and

• Category 7- Land Applicat ion, Feed Storage, Settli ng Basins, Composting, and

Manure Disturbance: Not included due to limited data on the VOC emissions at

these sources.

The emission categories listed above contribute to emissions in the following emission sources (locations) on a CAF are:

• Feed,

• Housing,

• Land Application (if applicable),

• Milking Center (if applicable),

• Liquid Waste Handling S ystems (if applicable), and

• Solid Waste Handling Systems (if applicable).

Not every facility has all of the above emi ssion sources due to differences in operating and farming practices.

G. Emission Factors

To calculate source emissions, reductions, and cost effectiveness of control measures, staff required emission fact ors. The emission reduction calculations are performed using the most recent emission factors acc epted by the District at the time of the

calculation.

Emission factors come from a variety of sources:

• The emission factor for swine, rabbits , horses, sheep, and goats are based on a metabolism study conducted in 1938 by Benedict and Ritzman. This study

measured methane in animals includi ng an elephant, a horse, seven (7) Holsteins, four (4) Jerse ys, and a Hereford cow. This study and the subsequentSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 18 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 research papers based on it remain the most currently published and reviewed source of emission factors for several specie s. Several most recent articles have reported different emissions from these operations and emission sources. However, those emission factors tend to be inconsistent, possibly due to variation between facilities, and are not co mplete. Staff was unable to locate comparable emission factor data that addressed all emission sources on these facilities. Therefore, the Ritzman study and Ritzman-ba sed studies are currently considered the most complete, published, and peer reviewed source of emission factors for these facilities. Additionally they are the factors listed in the ARB October 2003 interim proposed report on emission factors.

• The remaining emission factors are thos e currently used by the District's Permit Services for permitting purposes. Those factors are based on the 2005 California Department of Food and Agricult ure and Foster Farms source test of a chicken broiler facility; information fr om the Dairy Permitting Advisory Group (DPAG) (see www.valleyair.org/busind/pto/dpag/ dpag_idx.htm for details); and ASAE manure producti on equivalents.

Table 4 details the emission factors, based on these sources, which will be used for calculation purposes. As not ed previously, the emission factors may be revised in the permitting process to reflect the la test approved research information.

Table 4: Emission F actors (as of 4-26-06)

Animal Type VOC Emission Factor (lb/hd-yr) Milking Cow 19.3 to 21.7* Dry Cow 11.9 Heifer (15-24 months) 8.3 Heifer (7-14 months) 7.2 Heifer (4-6 months) 6.6 Calf (under 4 months) 6.2

Feedlot Cattle 11.1 Laying Hens and Associated

Birds 0.05

Broiler Chickens and

Associated Birds 0.025

Turkeys and Associated Birds 0.10

Swine 4.6

Rabbits 0.19

Horses 6.7 Goats and Sheep 0.96 * The emission factor for lactating cows vari es based on the type of housing. Cows in a complete flush dairy with no freestalls have an emission factor of 19.3 lb/hd-yr and cows in a complete flush dairy with freestalls have an emission factor of 21.7 lb/hd-yr. On theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 19 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Total VOC Emitted

by CAFs (lb/yr) Total VOC Emitted b y CAFs (tons/day) Total VOC Emitted by Large CAFs (lb/yr) Total VOC Emitted by Large CAFs (tons/day)

Milk Cows 37,432,525 51.2 8 26,951,418 36.92
Beef Cattle 2,042,955 2.80 1,940,807 2.66
Other Cattle 11,355,375 15.56 10,795,230 14.79 Poultry 2,583,221 3.54 1,574,625 2.16
Swine 729,266 1.00 414,000 0.57
Other Animals 296,383 0.00 0.00 0.00
Total Animals 54,439,725 74.57 41,676,080 57.09 Table 5: Total 2005 VOC Emissions from CAFs in the SJVAB website the 21.0 lb/hd-yr value is listed bec ause it is the weig hted average of the

number of animals in facilities with frees talls (71%) and the number of animals in facilities without freestalls (29% ). Specifically, the calculat ion is: 21.7 x 71% + 19.3 x 29% = weighted emission fa ctor = 21.0 lb/hd-yr.

H. Animal Inventory and Emissions

Staff utilized the 2002 USDA census, industry data, and California Air Resources Board documents to estimate the VOC's emitted by CAFs in the SJVAB. The methodology is further explained below; Tabl e 5 summarizes the results.

Dairy

Staff utilized the California Department of Food and Ag (CDFA) report entitled

“ California Agricult ural Statistics 2004 ." The numbers are shown in Table 6. These numbers only include milking and dry cows, not heifers that have not calved or calves.

Table 6: Number of Milk a nd Dry Cows (CDFA Data 2004)

County 2002 2003 2004 Projected

2005* Fresno 86,115 90,345 95,577 99,878 Kern 85,830 98,478 121,147 126,599 Kings 146,545 153,475 162,656 169,976 Madera 49,899 57,099 63 ,934 66,811 Merced 224,895 224,734 237,854 248,557
San Joaquin 99,828 106,162 103,619 108,282

Stanislaus 164,558 177,432 178,420 186,449 Tulare 424,643 437,476 442,853 462,781 Total 1,282,313 1,345,201 1,406,060 1,469,333 *The growth from 2002 to 2003 was approx imately 4.9% and t he growth from
2003 to 2004 was 4.5%. In order to be cons ervative, staff assumed a growth of
4.5% for 2004 to 2005.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 20 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Total

Animals VOC Factor (lb/hd/yr)

from Table 4 Total VOC

Emissions (lb/yr) Animal

Included In

Rule VOC Factor (lb/hd/yr) Total VOC

from Animals

Included in

Rule ( lb/ y r )
Milk Cows 1,266,666 21.00 26,599,994 912,000 21.00 19,151,996 Dry Cows 202,667 11.90 2,411,733 145,920 11.90 1,736,448 Heifers (15-24) 430,667 8.30 3,574,533 310,080 8.30 2,573,663 Heifers (7-14) 367,333 7.20 2,644,799 264,480 7.20 1,904,256 Heifers (3-6) 202,667 6.60 1,337,600 145,920 6.60 963,072
Calves 139,333 6.20 863,866 100,320 6.20 621,984
Total Cows 2,609,333 37,432,525 1,878,720 26,951,418 Table 8: Total 2005 Dairy Animals in SJVAB In order to estimate the number of support stock at a dairy, ratios were developed using 216 dairy applications submi tted to the District. Based on those applications the following ratios, listed in Table 7, were dev eloped. These ratios represent the number of each type of animal.

Table 7: Ratio of Each Type of Dairy Cow to Milkers

Support

Animals to

Milkers Dry

Cows

to

Milkers Heifers (15- 24 mo) to

Milkers Heifers (7-14 mo) to

Milkers Heifers (4-6 mo) to

Milkers Calf (<4 mo) to

Milkers

107% 16% 34% 29% 16% 11%

Before the above ratios can be applied to the CDFA milk and dry cow numbers to estimate a total number of head, the number of dry cows nee ds to be subtracted from the milk and dry cow numbers. Based on the ratios above, 16% of cows are dry cows when compared to milk cows, therefore the calculations would be as shown in the example below:

1,469,333/1.16 = 1,266,666 milk cows 1,266,666 x 0.16= 20 2,667 dry cows 1,266,666 x 0.11 = 139,333 calves

Now we can use the ratios in Table 7 to estima te all the other types of cows at a dairy.

Staff assumed, based on the ARB's June 23, 2005 Staff Report for Confined Animal Facilities page iii, that 72% of the dairy cows would be included in this regulation.

Furthermore, since the APCO Report noted that t he 19.3 lb/hd-yr factor did not consider all emission sources and that the majority of facilities have freestalls, in order to be conservative, Staff utilized the weighted emission factor of 21.0 lb/hd-yr listed on the District's web page for dairies.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 21 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Total

Animals VOC Factor (lb/hd/yr)

from Table 4 Total VOC

Emissions (lb/yr) Animal

Included In

Rule VOC Factor (lb/hd/yr) Total VOC

from Animals

Included in

Rule ( lb/ y r )

Total Beef 184,050 11.10 2,042,955 174,848 11.10 1,940,807

Total Other Cattle 1,605,000 7.08 11,355,375 1,524,750 7.08 10,795,230

Total 1,789,050 13,398,330 1,699,598 12,736,037 Table 9: Total 2005 Beef and Other Cattle

Total

Animals VOC Factor (lb/hd/yr)

from Table 4 Total VOC

Emissions

(lb/yr) Animal

Included In

Rule VOC Factor (lb/hd/yr) Total VOC

from Animals

Included in

Rule ( lb/ y r )

La y ers 11,717,799 0.050 585,890 7,265,035 0.050 363,252

Broilers 47,608,059 0.025 1,190,201 29,540,054 0.025 738,501

Turke y s 8,071,297 0.100 807,130 4,728,720 0.100 472,872

Total 67,397,155 2,583,221 41,533,809 1,574,625 Table 10: Total 2005 Poultry Animals Beef and Other Cattle

The following table includes other cattle fac ilities in the San Joaquin Valley, from a USDA California Agricultural Statisti cs 2004 Report and beef on feedlots from the

California Farm Bureau Federation. Staf f assumed, based on the ARB's June 23, 2005 Staff Report for Confined Animal Facilities page 8, that 95 % of the beef cattle and other cattle would be included in this regulation. This is based on the assumption that a

similar number of beef and other cattle would be included in th is rule as feedlot cattle listed in the ARB Staff Report.

Furthermore, staff assumed that there were equal numbers of each type of heifers and

calves at the other cattle facilities theref ore, averaged the emissi on factors for heifers

and calves in order to obtain the emission fa ctor for other cattle. This was used to develop Table 9.

Poultry and Other Animals

Staff obtained an estimate of t he number of layers in the SJVAB from the USDA census data. Since the ARB Propos ed Emission Methodology assume d no significant growth for layers, staff assumed that the layer population has been relatively constant since 2002. Based on ARB June 23, 2005 Public Hearing to Cons ider the Adoption of a Regulation Establishing a Defi nition of BACT, staff assumed that 62% of the layers are housed in large CAFs.

Staff obtained estimates of the number of broilers and turkeys in the SJVAB from the California Poultry Federation. Based on this information, staff determined the number of turkeys and broilers housed in large CAFs.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 22 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Total

Animals VOC Factor (lb/hd/yr)

from Table 4 Total VOC

Emissions

(lb/yr) Animal

Included In

Rule VOC Factor (lb/hd/yr) Total VOC

from Animals

Included in Rule (lb/yr)

Rabbits 3,903 0.190 742 - 0.190 -

Goats 34,160 0.960 32,794 - 0.960 - Sheep 273,800 0.960 262,848 - 0.960 -

Swine 158,536 4.600 729,266 90,000 4.600 414,000

Total 470,399 1,025,649 90,000 414,000 Table 11: Total 2005 Other Animal s Staff obtained an estimate of the number of rabbits, goats, sheet, and swine in the

SJVAB from the USDA census data. Since ARB Proposed Emission Methodology assumed no significant growth for non-cattl e, staff assumed that the non-cattle population has been relatively constant si nce 2002. Based on the District's permit database, staff found that approximately 90,000 swine ar e housed in large CAFs and no rabbits, goats, or sheep in the SJVAB are housed in large CAFs. This is

illustrated in Table 11.

I. Industry Description

The SCAQMD's dairy rule includes all fa cilities with 50 cows of any type, but the average dairy in SJVAB is over twice the size of dairies in the SCAQMD. Furthermore, the majority of the dairies in the SCAQMD are scrape dairies, many of which transport their manure off the dairy and into the SJVAB . In 2003, according to the Santa Anna Regional Water Quality Boar d, over 157,400 tons of m anure was shipped from the Chino Basin to the SJVAB. Many of t he SJVAB dairies use a flush waste control system instead of scrape waste removal system . Furthermore, dairies in the SJVAB do not typically ship manure out of the Valley but efficiently reuse their manure and flush water on adjacent or nearby crops. Therefor e, staff does not believe the SCAQMD dairy operations are comparable to the SJVAB dairy operations.

In terms of size of facilities, a signific ant number of CAFs woul d be below the proposed Rule 4570 applicability thresholds. Informati on from the California Poultry Federation, District's permit database, and CDFA estimates and surveys was used to identify all other facilities that would likely be required to implement practices that they do not already utilize. Please note that a signi ficant number of CA F already utilize enough mitigation options listed in the rule to comply with the rule requirem ents. Staff estimated

the number of swine facilities affected by using 2002 USDA census data. By subtracting the maximum and minimum number of swine in facilities with fewer than 1,000 head from the tota l number of swine in each county, staff estimated the number of

swine facilities that would be affected. This is summarized in Table 12.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 23 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Table 12

Estimated Number of Facili ties Affected by the Rule Animal Type Number of Large
CAFs Number of Facilities That Will Likely Be Implementing New

Practices Dairy 430 233

Beef Feedlots <16 6

Other Cattle Operations <16 5

Swine 1 to 3 1 to 3 Poultry <61 0

J. Source Growth

Overall, the livestock inventory in the SJVAB increased between 2 and 6% per year over the last 12 years. A significant portion of this growth is due to increases in the number of milk cattle. According to the USDA 2002 Census data and California Department of Food and Agriculture (CDFA) Statistics Annual from 1998 and 2002, the inventory of milk cattle in the SJVAB in creased over 30% from 1997 to 2002. Local county agricultural reports show that the in ventory of milk cows increased 2 to 4% between 2002 and 2003. In contrast, USDA c ensus data indicate relatively stable or decreasing populations of beef cattle, hog, la yer and broiler chicken, turkey, ducks, and geese from 1997 to 2002. Based on CEQA pr ojects submitted to the District, the inventory of dairy cattle in the SJVAB would increase over 25% in the next three years, if all the proposed projects we re completed. Although it s hould be noted that some of the CEQA projects may not be completed. Therefore, st aff assumed a conservative 4.5% growth for the dairy industry based on historical data from CDFA.

III. EMISSION CONTROL TECHNOLOGY

This section summarizes the requirement s for control and the possible control techniques for reducing air emissions from CAFs. The information assembled was obtained through a review of available literatu re and research. The goal of the literature review was to identify possibl e controls. Some of these controls do not appear in the rule as mitigation measures or on any lis t due to a lack of scient ific data regarding VOC reductions. However, they ar e identified in this report to provide owners/operators with ideas of some mitigation measures t hat have been proposed as potential mitigation measures and, with further information, ma y be approved as alternative mitigation

measures.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 24 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 A. Technology Requirements

Best Available Control Te chnology (BACT) as a New Source Review Requirement

With the changes to the CH&SC and the result ing loss of exempti on from permitting of agricultural sources of air pollution (CH&SC 39011.5 (b)), new or expanded CAFs may now be required to undergo the BACT proce ss as a requirement under New Source Review (NSR). District Rule 2201 (New and Modified Stationary Source Review Rule) implements state and federal requirements under Title I, Part D and requires BACT for

new sources or sources under going modification with emissi on increases that are above the de minimis value (two (2) pounds per day of VOC). BACT provisions would apply to sources which are subject to District permitt ing requirements and that emit or may emit one or more affected pollutant, ei ther as a “major” source subj ect to Title V permitting or

as a source with actual emissions which are 50% or more of any major source

thresholds.

Beginning July 1, 2004, large CAFs, as def ined by the ARB, and CAFs with emissions
that reach or exceed 50% of t he major source threshold were required to obtain permits. The existing sources that apply and receive pe rmits are not reviewed as “new” sources,

but rather as sources with a “l oss of exemption.” This means that BACT is not required, but the source may be subject to emi ssion reduction requirements under other local prohibitory rules, which are local ru les other than permi tting rules.

Best Available Retrofit Control Technology (BARCT) Requirement for Large CAF

As mentioned previously, CAFs defined as “large” by the ARB will be required by Proposed Rule 4570 to submit emission miti gation plans. The level of mitigation required by the CH&SC is BARCT. This te rm characterizes a standard of emissions

control for existing , traditional sources. Under f ederal air pollution programs for traditional sources, different levels of control are expected of new sources (best available) and existing sour ces (reasonably available), wit h the understandi ng that there are more options available at a more reas onable cost when a source is being designed, than there are after it is built, especially if it was built a long time ago. California law

established an intermediate level of control that is the “best available” for “retrofit” to existing sources, recognizing that the state’s air polluti on problems may demand more effective pollution control than what is usua lly considered “reasonably available.” Local air districts have adopted many rules to impl ement BARCT, including particulate control efficiency standards and limitations on exhaust pollutants and technology-based requirements that dictate the use of a particular control device or something that is equally effective.

BACT vs. BARCT As discussed above, the purposes of BACT and BARCT are different. BACT is designed to minimize the growth in future stationary source emissions; BARCT is designed to reduce current stationary source emi ssions. BACT is utilized in theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 25 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 permitting process on a case-by-case basis. BA RCT is considered for application on an industry-wide basis in the rule development process.

B. Feed and Silage Mitigation Measures

Feed According to National Research Council Guidelines

Dietary manipulation of feed formulations, a practice commonly used to improve animal health and productivity, has been shown to reduc e VOC emissions from cow flatulence (enteric) and manure. Emission reductions of at least 10% for ammonia, hydrogen sulfide, and VOC were found (Klaunser, 1998 J Prod Agric). However, studies regarding efficiency of dietar y manipulation to reduce VOC conflict. This may be due to

variations in feed formulations. Staff is considering the National Research Council's (NRC) recommendations regarding the nutrient requirement for different animals as an appropriate feed formulation to minimize VO C emissions from cow flatulence (enteric) and manure, while ensuring t hat animal health is not j eopardized. The National

Research Council considered environmental , animal productivity, animal health, and energy concerns in developing their guidance for nutrient requirements for animals. The guidance is located in the following publications:

• Nutrient Requirements of Beef Cattle, 2000;

• Nutrient Requirements of Dairy Cattle, 2001;

• Nutrient Requirements of G oats: Angora, Dairy, and Me at Goats in Temperate & Tropical Countries, 199 1;

• Nutrient Requirements of Horses, 1989;

• Nutrient Requirement s of Poultry, 1994;

• Nutrient Requirements of Rabbits, 1977;

• Nutrient Requirem ents of Sheep, 1985; and

• Nutrient Requirements of Swine, 1998.

As of May 19, 2005 these documents were available for purchase through links at: http://www.nap.edu/category.html?id=ag

Feeding Corn

In the Proceeding of the Symposium on the State of the Scienc e: Animal and Waste Management Jan. 2005 S.L. Archibeque et al presented a presentation titled "Feeding High Moisture Corn Instead of Dry Rolled Co rn Reduces Odor Production in Finishing Beef Cattle Manure Without Sacrificing Perfo rmance". This study found that cattle fed high moisture corn instead of dry rolled corn excreted less starch in their manure (starch

ferments to form volatile fatty acids which are a volatile organic compound) and less volatile fatty acids in their manure. Addi tionally, in the Journal of Dairy Science

87:2546-2553 article "The E ffect of Steam Flaked or Dry Ground Corn and Supplemental Phytic Acid on Nitrogen Part itioning in Lactating Cows and AmmoniaSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 26 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Emissions from Manure" by Burkholder et al found less starch in the manure of cattle fed steam flaked corn than dry ground corn.

Feed Removal

Research conducted by Dr. Chuck Schmid t at dairies within the SJVAB suggested significant emissions from feed in the feed lane. Therefore, regular cleaning of feed

from all areas of the facilit y are considered control measures. This is because by limiting the quantity of ti me that the feed is ons ite, one limits the quant ity of time that the feed may emit VOC. A dditionally, it minimizes the amo unt of moisture that comes in

contact with the feed. Sinc e the microorganisms that break down feed in a manner that releases VOC require moisture, by mini mizing the moisture one can minimize the microorganism's activity and thus VOC emissions.

Weatherproof Storage and Cove rs for Silage and Grain

Covering silage and grain may minimize the amount of area exposed to the environment, thus the amount of area from which VOC in the silage can enter the atmosphere. There are various options fo r covering silage and grain. These include, but are not limited to, silos, tarps, and bags. There are seve ral benefits of utilizing bags to store silage. Because of the low stor age height, there is less danger of falls from elevations. Additionally, t here is reduced spoiling of sil age. However, some of the disadvantages include added cost of approx imately $10 per ton of silage based on information found at the following website: http://bse.wisc.edu/hfht/tipsheets_html/s ilagebag.htm accessed 2/16/06. Covering silage and venting it to a VOC control dev ice is considered beyond BARCT because it has not been achieved in practice at fac ilities in the United States, although some

venders and researchers contend it is feasible. It would be a transfer of technology from the composting industry and require significant capita l investment (over $100,000 for materials and installation at a facility with 1,000 cows).

Leachate Management

Leachate from the silage contains water-soluble VOC. By collecting this and sending it to a treatment system, such as an anaerobi c digestion lagoon, the owner/operator minimizes the opportunity for the water in the leachate to evaporate and the VOC to be emitted into the atmosphere.

Eliminate Silage

Since fermenting processes, such as the pr ocess used to produce silage, emit VOC, substituting fermented feed (silage) for unfermented feed (grain) would reduce VOC emissions. However, due to feed availability and cost, this is considered extremely

difficult for facilities to im plement. This is primarily due to the Regional Water Quality Board requirements for land appl ication of animal waste in a manner that minimizes orSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 27 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 prevents nitrates and nitrites from entering ground water. One common method to do this is planting silage crops, which take in significant quantities of nitrogen, such as corn. Therefore, staff bel ieves that implementing this measure would result in significant increase in waste treatment costs (over $100,000 for a facility with 1,000 cows), such as installation of a denitrific ation system for animal waste; purchase of additional land; or transport of animal waste offsite.

Swine and Poultry Options

Research at the University of Mississippi State University and the International Journal of Poultry Science 2(5):313- 317, 2003 article titled "Reduction of Broiler House Malodor by Direct Feeding of a Lactobacilli Containing Probiotic" by Chang et al suggested that feeding broilers lactobacilli c ontaining probiotic reduced VOC emissions from the broiler house. The District's most recent BACT analysi s for broiler facilities noted that feeding the poultry lactobacilli containi ng probiotics likely reduces VO C emissions from poultry. Addition of enzymes, such as those fr om yucca and soybeans also may reduce VOC emissions by increasing the animal’s absorpt ion or digestion of nutrients thereby reducing the quantity of protein and volatile fa tty acids excreted in the manure and litter.

Information notes that poultry feed addi tives may be used to reduce the feed decomposition or oxidation in poultry feed, thus rate of VOC emissions.

Feed additives that improve digestion effi ciency have been studied on swine and poultry already being fed according to NRC guidelines for protein and nitrogen. In swine, research at the University of Purdue demons trated that the addition of 5% cellulose in feed formulation reduced VOC emissions by 11%. The study reported no adverse health effects from the addition of this quant ity of cellulose (Sutton 1998). The study

also noted reduction in VOC emissions wit h the addition of 10-ppm anthraquinone, and use of reduced protein diets wit h supplemented amino acids. In swine, the Journal of

Animal Science 2003 Volume 81:1754-1763 articl e "Ammonia, volatile fatty acids, phenolics, and odor offensiveness in manure from growing pigs fed diets reduced in protein by Otto et. al; Pur due 1998 Swine Day Report titled "Addition of Carbohydrates to Low Crude Protein Pig Diets to Reduc e Manure Nitrogen Excr etion and Odors" by Sutton et al; and Purdue 2000 Swine Day Repor t titled "Reduction of Odorous Sulfide and Phenolic Compounds in Pi g Manure Through Diet Modification" by Hankins et al found the following feed measures reduced volatile fatty acids in swine manure:

• Feeding probiotics;

• Feeding at least 5% cellulose in the diet;

• Feeding a casein based diet;

• Feeding an amino acid supplement ed diet with 2% sucrose thermal oligosaccharide caramel;

• Feeding a diet with no more than 10% crude protein with supplemented lysine, threonine, tryptophan, and methionine; and

• Feeling animals 10 ppm anthraquinone.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 28 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Since swine and chickens have a different digestive system and nutrient requirements from cattle, poultry and other animals, staf f was unable to deter mine whether or not these feeding strategies would reduce VOC emissions from othe r types of animals. See Figure 1 for a brief explanation of the difference between a ruminant (e.g. cow) stomach and a simple stomach (e.g. swine and chickens).

However, owners/operators of non-swine operations may ut ilize these options for their operation if they satisfy the requirements fo r utilizing these as alternative mitigation

measures.

Alternative Mitigation Measures

The following mitigation measures have been proposed and many are being researched as potential VOC mitigation measures. However, at the time of this report, there was Carbohydrates

Proteins

Fats Figure 1: Ruminants versus Simple Stomach Animals

Ruminants (cows, sheep, goats, deer, etc.)

Microbes

Feed HCl Pepsin Intestinal Enzymes Very Little Sugars

Amino Acids

VOC

Carbohydrates

Proteins

Fats Simple Stomachs (swine, poultry, etc.)

HCl Pepsin Intestinal Enzymes Sugars

Amino Acids

VOC

Source: Rumen Microbiology and Its Role in Ruminant Nutrition by Dr. James Russell.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 29 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 insufficient data for staff to det ermine that the measur es would result in volatile organic compound (VOC) emission reductions and not c ause harm to animals. Stakeholders may utilize these methods to comply with rule requirements if they could demonstrate, to the satisfaction of the ARB, APC O, and EPA that the measure achieves VOC reductions that are equal to or exceed the reductions that would be achieved by other mitigation measures listed in the rule t hat the owner/operator could have chosen.

1. Manage silage piles in a manner that mi nimizes exposed surface area (this was

removed from the list because staff wa s unable to locate appropriate standards for these practices); 2. Feeding high moisture or steam flaked corn instead of dry corn to swine; 3. Feeding high moisture feeds ot her than corn, inst ead of dry feed; 4. Feeding a diet containing probiotics to animals other than swine and poultry; 5. Feeding a diet supplemented with amino acids to animals other than swine and poultry; 6. Feeding a diet containing at least 5% cellulose to animals other than swine; 7. Feeding a casein based diet to animals other than swine; 8. Feeding an amino acid diet suppl emented with sucrose thermal oligosaccharide caramel to animals other than swine; 9. Feeding a diet with no more than 10% crude protein to animals other than swine; 10. Feeding a diet containing 10 ppm anthr aquinone to animals other than swine; 11. Feeding feed additives that reduce f eed decomposition for animals other than poultry; 11. Feeding a diet containing liquid instead of solid feed; 12. Feeding a manure acidifier; 13. Feeding high moisture or steam flaked corn to swine; 14. Only feeding silage that has a particle size of 10 to 20 mm; 15. Feeding high moisture grain; 16. Feeding animals elephant grass (a lso known as Napier grass and Pennisetum) instead of alfalfa hay; 17. Feeding animals bicarbonate; 18. Feeding animals forage instead of grain; 19. Supplementing animal diet with ruminally undegradable fiber; 20. Feeding a diet containing canola meal; 21. Feeding a diet containing sunflower seed; 22. Using silage additives such as sodium diacetate; 23. Using AIV silage; 24. Feeding a non-fiber carbohydrate supply to animals; and 25. Feeding a diet c ontaining supplemental fats.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 30 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 C. Housing/Animal Waste Mitigation Measures

Rapid Drying, Rapid Removal of M anure, and Moisture Minimization

In housing (including freestalls, pens, corrals, m ilk parlors, etc) moist conditions lead to anaerobic decomposition of manur e. Suppression of emissions of reduced gaseous compounds can be achieved by faster drying of animal waste, minimization of moisture, and increased removal frequency. Incr eased removal frequency reduces anaerobic decomposition by reducing t he amount of manure not ex posed to the surface and oxygen; minimizing the mois ture in the manure and feed th us minimizes the moisture needed by the microbes that dec ompose the manure to form VOC; and moving manure

and feed from areas with minimal controls to areas with significant controls (such as a treatment lagoon) reduces t he quantity of uncontrolled manure and feed emissions.

Elimination of Liquid Manure Handling

Poultry excrete a white solid called uric acid . Ammonia and VOC are emitted as the uric acid breaks down. The microbes needed to degrade the protein in the uric acid require moisture; therefore, moisture reduction is a significant means of reducing uric acid

breakdown and thus ammonia and VOC emissions . Hatfield noted that VOC emissions are negligible at poultry scrape facilities, but significant at facilit ies with liquid handling systems. Therefore, using a solid litter handling system exclusively is considered a

control measure.

In most other animals, significant VOC are emitted when the urease in urine mixes with

solid excretion. Moisture facilitates this mixing process. The microbes that break down the waste require moisture, thus drying t he waste and employing moisture minimization processes minimize the activity of thes e microbes. Several studies have found that volatile fatty acid emissions from manure incr ease with moisture. Koziel et al stated in their paper, “Measurements of Volatile Fatty Acids Flux from Cattle Pens in Texas, "[m]easured flux was propor tional to manure pH and moisture content" (Texas A&M University Paper #04-A-646-AWMAA). In the paper titled "Strategies to Reduce Manure Emissions," McGinn stated that "[a]dding more than 20 mm of water to manure increased volatile fatty acids emissions over a four-day period. Theref ore, solely utilizing a solid manure handling method for housing would reduce VOC.

Non-manure Based Bedding

As mentioned previously, manure breaks down in the presence of moisture to emit VOC. Housing tends to have high humidity and moisture due to misters, ani mal urination, and animal respiration. By using non-manure bas ed bedding you are minimizing the amount of manure products present in the housing that have the potent ial to emit VOC. Some types of non-manure based bedding are rice straw, almond hulls, cow waterbeds, and cow mats. Furthermore, you limit the size of separated solid stockpile s, which emit VOC,SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 31 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 on the facilities since in non-manure based bedding only a minimal quantity of separated solids is necessary.

Housing Animals in Buildings

One alternative would be to enclose the ani mal housing and vent the exhausted air to a secondary control device such as a biofilter. Plastic "curtains" similar to those used in poultry houses, in addition to traditional wa ll material, have been used for enclosures

vented to biofilters. Since all the anima l waste and enteric emissions in the house would be controlled by venting the exhaust air through a biofilter, management practices requirements including, but not limited to, di etary manipulation, animal waste removal frequency, and animal waste additives may not be necessary to ensure VOC reductions. It may allow owner /operator more flex ibility in managing their animals and their manure/litter. It may also result in fewer monito ring, recording, and testing requirements, since management practices in side the building may not be regulated. This option alone may achieve highest VOC r eductions of all the management practices proposed combined.

Furthermore, enclosing animals in buildings and venting the buildings to a biofilter may have benefits beyond air emissions. Dependi ng on the ventilation rate through the house animals may breathe fresher and cleaner air since air may be cycled through the

enclosure at a faster rate t han it would be in a fr ee stall or other housing with minimal or no mechanical ventilation. Dr. Terry Sm ith at Mississippi State University housed lactating Holsteins in a tunnel ventilated barn with misters and evaporative coolers and found an 1.8-2.7 kg/hd/day incr ease in milk production and 81% decrease in heat stress occurrences compared to animals housed in free stalls with fans and misters. Additionally, Hauls Dairy in Montana, a 1, 100 head facility, found that, by enclosing their milkers, they increased their milk production; decreased their calving interval by over a month; reduced the number of cattle with symptoms of heat stress; and reduced odor at the facility. However, Hauls did note that adequate ventilation is crucial to protecting animal health in the building.

Operations, such as poultry and swine, al ready typically house animals in enclosures with mechanical ventilation. Therefore, to ut ilize this control, such facilities would only need to install a VOC control system and increas e ventilation rates. Nicolai Pork in Hector, Minnesota; University of Minnesot a swine facility and University of North Carolina swine facilities used barn(s) vented to biofilters, which achieve capture and control efficiencies of approximately 80% (this is why an 80% capture and control efficiency was used in the VOC control opt ions). SRC in Urbana-Champaign, Illinois vent their swine-finishing house to a wet scrubber to reduce dust and VOC.

The University of Minnesota Extensi on publication number BAEU-18 dated March 2004 provides guidance for ventilation rates for dairy cows, chickens, turkeys, and swine housed in buildings. Additionally, it prov ides guidance for venting the building to a biofilter and configuri ng the biofilter. Cor nell University Dairy Facilities EngineeringSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 32 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Program has an interactive program to assist in designing and estimating the cost of a tunnel ventilated dairy barn. Please refer to the following website for further information: www.prodairyfacilities.cornell.edu /TunnelVent/Final_Report.aspx

However, this would be considered beyond BAR CT due to the high cost and the fact that it has not been achieve in practices at fa cilities similar in size to those defined as large CAFs by the ARB.

Thymol

Thymol is plant oil derived fr om thyme. This compound was tested by Vincent Varel of the United States Department of Agriculture, Agricultural Research Service. This was applied to the ground at cattle feedlots and swine housing. In multiple studies, thymol showed a reduction in volatile fatty acid (VFA ) emissions from manure. Thymol causes the pH of the manure to drop more rapidly, further inhibiting microbial activity and air emissions. In addition to reducing VFA emissions over 50%, it also reduced fecal coliform content in the waste. However, t hese results were from studies conducted for short period (less than a month) therefore addition al data is required to determine the long-term effects of these oils.

Due to the fact it has not been used at facilitie s similar in size to that defined as large CAFs by the ARB and is very expensive, staff considered this mitigation measure beyond BARCT.

Lime

Lime has been used by several facilities to mini mize moisture. Howeve r, it is extremely costly and in many cases not feasible due to soil quality and water quality issues. Therefore, it is considered beyond BARCT.

Vacuum Animal Waste and Apply Directly to the Land

While this would minimize emissions by mini mizing the moisture in manure and the time that it is stored in an uncontrolled manner, it is considered beyond BARCT due to the high capital costs of vacuum trucks.

Use Shade Structures Designed to NRCS Standards

This would minimize moisture, thus anaerobic decomposition of manure under the

shade structures. It would also minimize an imal movement, thus t he surface area over

which manure is excreted and VOC emitted. However, this option is extremely costly, thus considered beyond BARCT.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 33 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Alternative Mitigation Measures

The following mitigation measures have been proposed and many are being researched as potential VOC mitigation measures. However, at the time of this report, there was

insufficient data for staff to determine that t he measures would result in volatile organic compound (VOC) emission reductions and not c ause harm to animals. Stakeholders may utilize these methods to comply with rule requirements if they demonstrate, to the satisfaction of the ARB, APCO, and EPA, t hat the measure achieves VOC reductions that are equal to or exceed the reductions that would be achieved by other mitigation

measures listed in the rule that th e owner/operator could have chosen.

1. Acidification of manure;

2. Use of manure additives not listed in Proposed Rule 4570; 3. Use of potassium permanganate in manure piles or corral; 4. Use fresh water to clean the freestalls;

5. Use low biochemical oxygen demand water to clean the freestalls; 6. Use environmentally safe cleaning on degreasing products on dairy manure;

7. Pave feedlanes at least 8 feet on the corral side of the fence; and 8. Use of eugenol (may have water quality issues).

D. Solid Manure Handling

Cover or Eliminate Solid Manur e Piles During the Wet Season

As noted above, wet manure promotes anaerobic decomposition, which emits significant VOC. Therefore, practices, such as coveri ng piles that minimize exposure to moisture

also minimize VOC emissions.

Compost

Current research suggests that aerated stat ic piles (ASPs), in-vessel technology, and within vessel technology (i.e. Ag Bag) wit h the captured air vented to a secondary control may reduce VOC emissi ons from the pile by 23- 95%. Preliminary data from Schmidt/Card's 2004 ARB Research Sympos ium presentation suggests that solid storage may account for approximat ely three (3) percent on the emissions at a facility. Based on this estimate ASPs, in-vessel, and within vessel technologies may reduce emission on a facility by approximately 0.69%-2.85%.

In ASP composting, manure is mixed with other material and formed into piles that are mechanically aerated. There are two common methods of aer ation- either the compost pile is formed over a concrete floor with built -in vents to force air through the compost or the pile is formed around pipes attached to a bl ower that forces air through the pile. Both in-vessel and within vessel systems enclos e the compost mix in a bag, vessel, or structure and mechanically aerat es the mixture. In all the systems, the captured air isSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 34 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 vented to a secondary control device, a devic e to further reduce VOC emissions, such

as a biofilter.

It should be noted that the California Int egrated Waste Management Board regulations, including but not limited to California Code of Regulations (CCR) Title 14, Division 7, Chapter 3.1, Articles 1-4, ma y limit the materials that ma y be use for composting and/or place additional requirements on the facility depending on the type of material used in composting; origin of material used in composting, quantity of material used; and quantity of compost given aw ay or sold annually.

This is extremely costly and not achieved in practice at large CAFs, thus considered beyond BARCT.

Solid Waste Digesters

Anaerobic digestion has been used on swine and dairy operations for solid and liquid waste handling. Limited prelim inary research suggests that when the gas is captured and vented to a secondary control, up to 90 % control efficiency of VOC emissions from

the waste can be achieved from these technologies. Howe ver, these are extremely costly and producers note that they require si gnificant technical skill to operate, thus considered beyond BARCT.

Alternative Mitigation Measures

The following mitigation measures have been proposed and many are being researched as potential VOC mitigation measures. However, at the time of this report, there was

insufficient data for staff to det ermine that the measur es would result in volatile organic compound (VOC) emission reductions and not c ause harm to animals. Stakeholders may utilize these methods to comply with rule requirements if they demonstrate, to the satisfaction of the ARB, APC O, and EPA, that the measure achieves VOC reductions that are equal to or exceed the reductions that would be achieved by other mitigation

measures listed in the rule that th e owner/operator could have chosen.

1. Thermal Conversion (Including Combustion and Gasification Technologies that burn wast e to produce energy or treat waste to produce fuels

are classified as "thermal conversion": and include direct combustion (burning with excess air to produce heat), pyrolysi s (thermal treatment in the absence of air, resulting in the production of pyro lysis oil and low BTU gas), gasification (thermal treatment at higher temperatures in an oxygen-restricted environment to produce a low to medium BTU gas), and hydrothermal liquefaction (thermal conversion of solids in a liquid stream to oils and char for separation and use as fuel). Many existing thermal conversi on technologies are not suitable for raw dairy manure due to the high-energy cost s to dry the manur e to an acceptable moisture level. Additionally thermal conversion has the potential to create airSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 35 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 emissions, although there are methods of controlling these air emissions. The University of Southern Illinois is te sting this potential control option.

2. Windrow Composting wit h Management Practices Some stakeholders have suggesting managem ent practices such as controlling the moisture content, carbon to nitrogen co ntent, and porosity of compost piles to minimize VOC emissions from compost piles. As of the date of this report staff was not able to find significant informa tion specifying the appropriate parameters

for these measures and demons trating that these measur es would result in VOC

emission reductions

E. Solid Separators

Solid separators may be used to reduce loadi ng of the lagoon, extract separated solids for composting and/or bedding, and serve other purposes on the facility. There are two categories of solid separation systems -- source separation systems and delayed separation systems. While so lid separation can occur at any point during manure handling and treatment processe s, the separation methods used closest to the point of origin (source separation systems) are signi ficantly different than the methods used

after the manure has been di luted or stored.

Belt separation is one the most common types of source separation. Conveyor belts are placed beneath the animals, typically under a slatted floor. The belt is concave or positioned at an angle allowing the urine to fl ow into a gutter and away from the solids dropping onto the belt. The liquids flow down the gutter by gravity and into a collection tank. The manure solids are scraped off the bel t and into a separation collection area. Belt systems have been used in poultry operati ons for about 30 years (van Kempen, 2003), have a life expectancy of eight to ten years, and require minimal maintenance. They have also been used routinely in swine facilities.

The alternative to source separation is del ayed separation, separation after the urine

and fecal matter have been mixed or diluted with flush water. Gravity, mechanical, and chemical are the main ty pes of solid separation.

Gravity separation, also called passive separ ation, uses the natural downward force of gravity to separate the liquid fr om the solids. Solids denser than the liquid settle to the bottom and solids lighter than t he liquid form a crust on the t op. Liquid is removed by pipes between these two regions or by over flow where the liquid, when it reaches a certain height, simply flows over a small dam into another basin. Gravity systems can be settling channels, settling basins, or se ttling ponds. All of these systems require additional storage for the separated liquid, as well as periodic removal of the settled solids. Current research suggests a solid removal efficiency of 7% to 65% depending

on factors such as the initia l quantity of solids in the waste and the retention time.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 36 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 An alternative to gravity separation is mechanical separation. This relies on a combination of moving parts and gravity to separate manure solid s from the waste stream, mostly utilizing the si ze of the solid particles to achieve separation. While mechanical processes can achieve separation faster than gravity pr ocesses, there are tradeoffs, for example, the expense of t he power to drive the machinery and the maintenance required of moving gears.

Mechanical systems include sloping stat ionary screens, vibrating screens, screw presses, drag chain separator s, roller presses, and centri fuges. A sloping stationary

screen is the most common method of mechani cal solid separation. The slurry is deposited at the top edge of t he sloping fabric screen where the screen is virtually vertical. As the slurry moves down the slop e, free liquid flows through the perforations. The relationship between efficiency and mesh size is inverse. Vibrating screen systems

are the second most common mechanical method for solid separation. They are similar to the sloping screen, except they vibrate to keep the perforations clear and shake solids off the edge of the screen. A different mechanical system is the screw press. The slurry enters a hopper, and then the screw pr ess, which consists of a screw auger rotating inside of a cylindrical perforated screen. The slurry is put under pressure by the auger as it moves toward the discharge end . Adjusting a counterweight at the discharge end of the system can alter the effici ency of solid separation. Another system is the drag chain system. The slurry is applie d to a perforated screen. Free liquid flows through the perforations and into a collection basin. Chains equipped with paddles pass

over the surface of t he screen. Variations in solid cont ent affect the e fficiency of this method. The roller press system consists of a roller press containing a rotating perforated drum and one or more rollers. Fi rst, the slurry enters the drum where free liquids pass through the perforations, and the sl urry moves to the end of the drum. As the slurry moves under the rollers, more liqui d is squeezed out. Solids are scrapped off the drum and roller apparatus and into a storage container. Another method is a centrifuge where the centrifuge rapidly spins t he slurry, pulling the liquids to the outside through perforations. The solids remain on t he inside wall of the perforated drum.

There are varying opinions regarding the typi cal percent solid removal from different types of solid separators as shown in Table 13.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 37 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Table 13
Estimates of Solid Removal with Mechanical Separation Methods

Percent Removal Source 10%-98% Separating Fact from Fiction, Alan Newport, Hay and Forage Grower, Sept. 2004. 15%-65% Iowa State University, Selection and Performance of mechanical Solid-Liquid Separ ators, Robert T. Burns, rburns@iastate.edu. 17%-60% University of Tenn., Perf ormance Testing of Screw-Press Solid Separators, Robert Burns and Lara Moody, P.O Box 1071, Knoxville, TN 37901-1071. 30%-40% University of Ill. at Urbana-Champaign, Swine Odor Waste Management Paper 4, 2005.

50%-70% Miner 2002.

Several factors including the size of the s eparation screen (which typically range from 0.010-0.150 inch and may be as small as 0.007 inches or as large as 0.025 inches);

and initial solid concentrati on of the manure can affect the solid removal efficiency

F. Liquid Manure Mitigation Measures

Volatile organic compounds (VOC) are fo rmed as intermediate metabolites in the degradation of organic material in manure and litter. Under aerobic conditions, any VOC formed are rapidly oxidized to car bon dioxide and water. Under anaerobic conditions, complex organic compounds are degraded microbially to volatile organic acids and other volatile organic compounds, wh ich in turn are converted to methane and carbon dioxide by methanogenic bacteria. When the activity of the methanogenic bacteria is not inhibited, virtually all of the VOC are metabolized to simpler compounds and the potential for VOC emissions is nom inal. However, inhibition of methane formation results in a buildup of VOC in the manur e and ultimate volatiliza tion to the air. Loading more solids in the liquid storage syst em than the system can handle causes

this. VOC emissions will be minimal from a properly designed and operated stabilization process such as anaerobic l agoons. However, VOC emissions will be higher from storage tanks, ponds, overl oaded anaerobic lagoons, and land application sites. (EPA 2001)

Minimize Animal Excretions in Lagoons (only stormwater, boiler blowdown, etc.)

By limiting the lagoon to wast ewater not from freestall flus hing, the organic loading and

thus VOC emissions from the lagoon will be less.

Phototrophic Lagoon

In Zahn et al's 2001 study, lagoons with Bact eriochlorophyll A concentrations above 40

nmol mL -1 , phototrophic lagoons, showed lower emi ssions of VOC than other swineSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 38 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 management systems. Overall, a lagoon with a phototrophic lagoon had 80% to 90% less VOC emissions per head on the average than a lagoon that was not phototrophic (Zahn 2001). Reductions of 80% to 93% of VOC were also observed in phototrophic swine lagoons following a photosynt hetic bloom according Do 2003.

Lagoons Designed In Accordance with USDA/NRCS Recommendations

The USDA NRCS Agricultural Waste Managem ent Field Handbook offers guidance on building and designing anaerobi c and aerobic lagoons. In general, lagoons that meet the guidance parameters are expected to have lower VOC emissions than lagoons with smaller dimensions, lower dissolved oxygen content, or higher loading. In general, aerobic lagoons are shallow, 2-5 feet deep and loaded so that the dissolved oxygen concentration is approximately double the biological oxygen demand. Anaerobic lagoons tend to be sized so that there is sufficient water to dilute the animal waste entering the lagoon such that there is no mo re than 11 pounds of volatile solids per 1,000 feet 3 per day entering the lagoon. If the lagoon does not have sufficient volume to accept all the waste sent to the lagoo n and not exceed 11 pounds of volatile solids per 1,000 ft 3 per day limit, pretreatment of liqui ds entering the lago on may be used. This pretreatment may be solid separation. The solids s eparated from the liquid would

be handled similar to other solids on the facili ty and the liquid, with less volatile solids, would be sent to the lagoon.

Lagoon pH

The solubility of VOC is pH dependant, thus measures to maintain the pH within the range that maximizes VO C solubility would minimize VOC emissions.

Complete Aeration/Aerobic Lagoons

In this system, sufficient concentration of dissolved oxygen is maintained to enable aerobic digestion to occur. Aerobic digestion is the decomposition of organic compounds by microbes in an oxygen-rich environment. The microbes reduce the organic compounds in the wast e to carbon dioxide, wate r, nitrates, sulfates, and biomass (sludge). According to Dr. Ruihong Zhang of UC Davis, complete aeration can be achieved with dissolved oxygen concentrations of greater than 2. 0 mg/L. However, this has not been achieved in practice at CAFs in the SJVAB and consumes significant energy, thus is considered beyond BARCT.

Lagoon Loading

This measure would minimize VOC by prom oting phototrophic conditions, however is considered beyond BARCT due to the fact CAFs typically do not measure these parameters, thus may need extensive tr aining to understand and maintain these parameters.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 39 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Use Non-standard Equipment or Chemical Additives with the Solid Separator

This method requires extensive capital expense and is typically beyond what is utilized at CAFs, therefore c onsidered beyond BARCT.

Covered Lagoon with Gas Vented to a Control Device

Covers may be used to capture the gas pr oduced by reactions in the lagoon and send the gas to a secondary VOC control device, which includes, but is not limited to an anaerobic digester generating el ectricity. Storage covers need to be acceptable by local mosquito abatement district regulations. T hese vary from district to district, but in general, districts require that the cover not be liquid pe rmeable and completely cover the lagoon with no gaps that woul d allow mosquito access to the liquid or be removable so that mosquito abatement personnel can treat the lagoon if need ed. There are two main storage cover designs: bank-to-bank and balloon.

Bank-to-bank covers extend across the entire span of the storage facility. The edges

are buried in trenches around t he perimeter of t he pond, pit, basin, channel, or lagoon.

Bank-to-bank covers are continuous with t he ground surface or extend only slightly above the ground. The design should include fl oatation devices to keep the cover from sinking into the manure. Water pumping eq uipment may be required to keep the cover free of standing water. This design c an create an anaerobic environment, depending on the specific design and materials used.

A variation of the bank-to-bank cover design is the balloon cover. These are essentially fabric pulled over the surface of the storage facility and kept aloft with fans and blowers. The fans and blowers create air pressure to infl ate the cover. Pre-cast concrete posts or stainless steel poles may be used as supports fo r the cover. A matrix of ropes placed on the manure may also be used to keep the cover from sinking into the manure in case of a power loss. These covers are typically not appropriate for creating anaerobic conditions since air is pumped into the headspace above the manure. Once again, the edges of the cover are buried in trenches around the perim eter of the lagoon. There are various materials that may be used for covers including, but not limited to hypalon 45, polyvinyl chloride (PVC), PVC coated with acrylic or hypalon, estane polyurethane, polyethylene,

and others.

However, this requires capital expenses beyond what is considered BARCT.

Alternative Mitigation Measures:

The following mitigation measures have been proposed and many are being researched as potential VOC mitigation measures. However, at the time of this report, there was

insufficient data for staff to det ermine that the measur es would result in volatile organic compound (VOC) emission reductions and not caus e harm to animals. Stakeholders may utilize these methods to comply with rule r equirements if they de monstrate, to theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 40 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 satisfaction of the ARB, APCO, and EPA, that the measure achi eves VOC reductions that are equal to or exceed the reductions that would be achieved by other mitigation

measures listed in the rule that the owner/operator could choose.

1. Chemical Oxidation Chemical oxidants can be applied in liquid form to liquid manure systems to oxidize VOC. Agents such as pot assium permanganate and hydrogen peroxide may be applied to the system, at the surfac e, to reduce emissions. However, a large amount of these types of additives is typically required due to the high organic matter content of animal manure. The emission reductions achieved by these additives also appears to be short term, requiring frequent applications to consistently reduce gaseous emissions. There are several venders of these

chemical oxidants and these chemic als have been utilized on swine and dairy facilities, however, due to the cost and other concerns, their use is not widespread.

2. Ozonation Ozone has been used to reduce gaseous emissions from manure slurries by bubbling or diffusing it through dairy slu rry. However, ozone must be produced on-site, which requires costly generation and application systems.

3. Microaerobic Biological Nu trient Management Practice In this system, waste products are colle cted and mixed with wate r. The mixture is pumped through a contact chamber and t hen a coarse solid separator. The clarified liquid fraction containing dissolved solids, suspended solids, and a suspension of microbial cells flows to the next unit process in the treatment systems, the bioreactor. The li quid then passes through anaerobic and anoxic zones. According to technology vender s, the majority of the VOC and VOC precursors are metabolized an d incorporated into microbi al biomass. Based on the Final Dairy Permitting Advisory Gr oups (DPAG) Report this has a control efficiency of approximately 79% for t he emissions from liquid manure handling and approximately 52% for emissions from land application. The District has reviewed the provided information about this technology and it appears that it has the potential of reducing VOC emissions. Additional informati on, such as that specified in the Final DPAG Report, will be required to fully evaluate such a system. CAF owners/operat ors would include the additional information should they wish to propose such systems as alternative mitigation measures under

Section 5.0 of Rule 4570.

4. Microbial Lagoon Additives In this method a mixture of microbes and, in some cases, nutrients and/or media are added to the lagoons on a routine basis. Venders suggest that this technology reduces VOC emissions, m anure sludge buildup, odors, preserves nutrients, reduces nitrates, reduces amm onia emissions, reduc es flies, and many other things. It has been used at numer ous dairy and poultry facilities, howeverSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 41 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 there is not sufficient data available to det ermine the effect of this technology on

VOC emissions.

5. Aquatic Cropping In this option alga is grown in engi neered ponds, raceways, or lagoons. Some suggest that the algae incorporate ni trogen, phosphorus, and VOC precursors into their biomass. The algae coul d then be harvested and used as a slow release fertilize; protein feed; component in make-up production; or other use.

6. Natural Crust Manure Storage Cover A manure crust typically forms if la rge amounts of solids are added to a liquid manure storage unit. Some belie ve that the crust serves as a biological cover

that would reduce VOC emi ssions. Others believe t hat by increasing solid loading to form this crust one would increase VOC emissions.

7. Elimination of Processing Pit Some believe that the processing pit is an additional emission unit that causes increase VOC emissions. They note that th e manure in this pit is not treated; the pit has solids levels above 1%; in some cases the pit is stirred; and the solids have a potential of settling and forming anae robic conditions—all of which could

lead to increased VOC emission s. Others believe that the processing pit is not an additional emission unit and explain it as simply an expanded use of the pump pit for the solid separator.

8. Wet Combustion System This process involves adding oxygen and ba cteria. The technology introduces oxygen into pond systems with th e intent of raising the oxygen levels. Bacterial is introduced on a daily basis.

9. Reciprocating Water Technology In this process, organic matter is oxidized and nitrogen is removed via biological

nitrification and denitrification.

10. Rotating Biological Contactor In this process, a fixed film of micr oorganisms rotates, much like a water wheel,

in and out of an effluent stream ther eby exposing the attached biofilm to alternating aerobic and anaer obic conditions. Organic compounds are oxidized.

G. Crop Application

Land Application

Current research suggests t hat the majority of emissions emitted during land application of manure are emitted during t he first 24 hours. Therefore, rapid land incorporation,

whenever feasible is considered a control measure. This incl udes rapid incorporation ofSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 42 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 waste into the soil by tilling, injection, and other methods. This type control method, based on SCAQMD PR1127 Staff Report has a cont rol efficiency of approximately 23%. Furthermore, by only applying waste with minimal biological activity, either waste that has already by treated or with low moistu re content, VOC emitted by biological degradation of manure is minimized.

Land application at an agronomic rate can be a cost-effective and sustainable practice that can build soil tilth, increase the wate r holding capacity of the soil, and provide essential nutrients for plant growth. T he land application options are designed to provide and ensure maximum rule flexibility and allow land application of animal waste. Nothing in the rule places minimal or ma ximum limits on the quantity of manure applied to the land. Furthermore, the owners/operat ors have the opportunity to choose when to land apply waste, either by timing of anima l housing removal or only applying waste that

has been treated or with dried.

It is understood that a balance between manure incorporation and conservation tilling must be struck-- incorporation disturbs the soil surface and reduces plant residue cover,

which can lead to erosion. Ther efore, tilling options may not be feasible for all facilities.

It is further understood that these measures are not alwa ys feasible, for example once crops grow a certain height the use of injection equipment may cause crop damage-- therefore injection methods are not to be us ed at these times. Additionally, in wet weather the vehicles used to transport t he manure could become stuck in the fields, thus at some times weather may cause this option to be infeasible . In such cases, farmers would likely choose the following mitigation measures:

• Only apply liquid manure at a rate that it is absorbed into the soil, thus no tilling would be required;

• Not apply liquid manure;

• Only apply solid manure with moisture content less than 50%, thus no tilling would be required; or

• Not apply solid manure.

Surface applied solid and slurry type manure ma y be incorporated into the soil by either disking or plowing. Liquid manure may also be injected using a mobile injection device attached to a tank. Incorporation is ex pected to reduce VOC emissions because the soil is expected to trap t he VOC below the surface and act a biofilter scrubbing and absorbing a significant portion of the VOC before they are able to escape into the atmosphere.

H. Secondary Controls

A secondary control is a device where air is exhausted to a control to further remove

VOC from the air stream. Air from com posting, digesters, enclosures, and covered lagoons, as discussed previously in this staff report, may be vented to a secondary control device including, but not limited to, biofilters and wet scrubbers. These systemsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 43 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 have routinely been used in the swine indus try and as well as some poultry and dairy

facilities. Most of these biofilters were des igned for ammonia or odor control rather than

for VOC control.

Biofilter

A biofilter is a control technol ogy that uses microorganisms to treat air emissions. They have been used at poultry, swine, and dairies (mo stly in colder regions where the cows are housed in barns), to control air c ontaminants, however there may be negative

animal health issues related to the use of biof ilters. A biofilter is simply a layer of organic material, referred to as biofilter medi a, that supports a microbial population. Mechanical and/or natural ventilation pushes air through ducts into the air plenum; empty space underneath the biof ilter. A fan then pushes the air up through the biofilter material. In the media, microbes convert VOC to carbon dioxide and water. Figure 2 below depicts an open-faced biofilt er system for a swine house.

Figure 2 Biofilter

Biofilter designs are based on the volumetric flow rate of the ai r to be treated, air

contaminants to be treated and the concentrations , media characteristics, biofilter size (area) constraints, moisture control, main tenance, and cost. Thes e parameters all play a role in either the efficient cleaning of airstreams or in the ec onomic operation of the biofilter. The ventilation rate required is dependent on temperature and the type, size, and number of animals in the building. V entilation design procedures can be found in the University of Minnesota Extension Pub lication MWPS-32, Ventilation Systems for Livestock House. Some building vent ilation rates are shown in Table 14.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 44 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Table 14 Typical Building Airflow Requirements

Facility Type Airflow Requirements (cubic feet per minute per animal space for warm weather)
Swine Nursery 35 Swine Finishing 120

Swine Gestation 150 Swine Farrowing 500 Broiler or Layer (5 lb live weight) 5 Turkey (40 lb) 32 Dairy Cow (1,400 lb) 470 Covered Manure Storage (per square foot of surface area) 0.1

( Source: Schmidt 2004)

Biofilters treating air from a manure storage unit may treat a smaller volume of air than animal housing, but the air will have a higher concentration of odorous gases. Typical

airflow rates from a covered manure stor age unit are 0.01 cfm per square foot of

surface area.

Media selection is another crit ical element because, for a bi ofilter to operate efficiently, the media must provide a suitable environm ent for microbial gr owth (including appropriate pH and temperature) and maintain a hi gh porosity to allow air to flow easy. A proven organic media mixture for anima l agriculture biofilters ranges from approximately 30:70 to 50:50 ratio by wei ght of compost and wood chips or wood shreds. The wood provides the porosity and structure while t he compost provides microorganisms, nutrients, and mo isture holding capacity.

The life of the media is typically at least three years and likely five years or longer. During this time, the media decomposes and becomes denser, which reduces the porosity (air space in the media) and incr eases the pressure or force needed to move the air through the biofilter medi a. This force is measured as the static pressure drop. A static pressure drop of ov er 50% of the design pressure , the pressure upon initial start-up, across the biofilter indicates the need to replace the media. (Schmidt 2004)

Ductwork and plenum construction are another cr itical component of a biofilter. Ducting

must be constructed to move the air from t he fans to the plenum of the biofilter. The ducts and plenum should be designed to keep the air velocity between 600 and 1,000 feet per minute. (Schmidt 2004)

Moisture control is also essential. Inadequat e moisture can allow the media to dry out, deactivating the microbes and creating cracks and channeling of air, which results in a reduction of filter efficiency. Too much moisture can pl ug some of the pore in the media, causing channeling and limiting oxygen flow in satu rated areas of the filter,SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 45 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 thereby creating anaerobic zones in the biof ilm. Recommended moisture content for biofilters range from 40-65% we t basis with optimum moisture content of 50% (Schmidt 2004.)

Finally, good weed prevention an d rodent control are essentia l. Weed growth on the

biofilter surface can reduce the treatment efficiency by causing air channeling and limiting oxygen exchange. Roots also contribut e to plugging of biofilter pores inhibiting the flow of air through the m edia. Rodents, such as mice , rats, rabbits, woodchucks, and badgers, burrow through the warm media dur ing the cold winter months causing channeling problems. Channelin g, as previously mentioned, reduces the biofilter efficiency by providing a means of air escapi ng the biofilter without completely filtering through the media and being comple tely treated by the microbes.

Gas Absorption

In a gas absorber, building air is collect ed and passed though an enclosed (typically packed) tower with the absorption media flo wing counter-current to the incoming air

stream. Gases in the air st ream diffuse into and are absor bed by the media. Although water is used as the scrubbing media in many applications, the absor ption of gases can be enhanced using chemical reactions between target gases and the absorbing media, such as using caustic solution to remove acidic gases. Some negative impacts associated with this option ar e the emissions from the gener ation of the electricity needed to convey air to the scrubber and dispos al of the absorbing media. It has been used in a study at the University of Minnesota, however staff was unable to find commercial CAFs utilizing this technology to reduce VOC.

Bioscrubber

The concept behind a bioscrubber is similar to that of biofiltration with the exception of the microorganisms, which are housed in an enclosed packed tower with water circulated counter-current to the incoming build ing air, instead of in a filter bed. As contaminated air is passed through the scrubber, water-soluble compounds are absorbed by the water and oxidized microbially. Some scrubber designs contain a vessel that is used as a biological reactor. Effluent from the scrubb er is routed to the

vessel where additional retention time is provided for microbial oxidation. No

information was found in the literature review regarding the ultimate disposal of the effluent from bioscrubbers. However, it is lik ely that this effluent could be land applied. Periodically the filt er media must be replaced due to decomposition and compaction. These have been utilized at swine operations with a reduction of over 80%, however they are not common at commercial operations.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 46 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 IV. MONITORING AND MEASUREMENT REQUIREMENTS (MMR)

The monitoring and measurement requireme nts, which include minimum testing frequency, are designed to minimize the co sts of testing for owners/operators while ensuring that adequate testing is conduct ed to demonstrate compliance with the appropriate mitigation measures and such m easures are operating in a manner that optimizes the VOC reductions.

Monitoring Requirements

The CH&SC 40724.6 requires that the District obtain sufficient information to develop an emission inventory for all po llutants. Since the emission inventory is dependent on the number of animals in the SJVAB and typica lly other agencies do not collect and publish data in sufficient detail (e.g. number of animals of each type in each county) to accomplish this, staff is requiring producers to provide this information to the District, upon request. Please note that owners may use documents, such as Regional Water Quality Board Waste Nutrient Management Plans that list the numbers of animals in each production group (e.g. calves, heifers, m ilkers, and dry cows) to comply with this monitoring requirement. The ru le will not require owners/operat ors to maintain a set of records exclusively for the use of the San Joaquin Valley Air District.

Other monitoring and testing r equirements only apply to facilities that choose mitigation measures where such monitoring or testing would assist in demonstrating compliance. This is to acknowledge that, based on current ly available information, these parameters are not necessary to determine an emission in ventory, unless the mitigation measures chosen are affected by these parameters. An example is monitoring feed content.

Table 15 below lists the feed mi tigation measures for dairies.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 47 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Table 15 Feed Mitigation Measures for Dairies A. Owners/operators shall in corporate at least four (4) of the following feed mitigation measures: Class One Mitigation Measures 1. a. Feed according to National Re search Council (NRC) guidelines. 2. a. Feed animals high moisture co rn or steam-flaked corn and not feed animals dry rolled corn. 3. a. At least once every fourteen (14) days remove feed from the area

where animals stand to eat feed. 4. a. At least once every fourteen ( 14) days remove spilled feed from the area where equipment travels to place feed in the feed bunk.

5. a. Remove uneaten we t feed from feed bunks within twenty-four (24)

hours of a rain event. 6. a. Feed or dispose of rations withi n forty-eight (48) hours of grinding and mixing rations. 7. a. Store grain in a weatherproof storage structure from October through May. 8. a. Implement an alternative mitigat ion measure(s), not listed above.

Facilities only choosing options A3, A4, A5 , and A6 would not need to maintain records of feed content, formulation, or quantity of feed additives used in order to demonstrate rule compliance since these m easures are not affected by this. However, a facility choosing option A1 may need to maintain the aforementioned records in order to demonstrate compliance.

Traditionally, the District has required test ing of VOC control devices every twelve

months to ensure that the device has not been damage d, degraded, or otherwise changed to the degree that it no longer achieved the desired redu ctions. More frequent testing is not required because it is a mec hanical device with clearly defined operating parameters which are not expect to change signifi cantly in time periods of less than a year. An example would be a biofilter. If the blowers are operating at a specific pressure, unless the biofilter media has been saturated, it has been well documented that specific VOC control efficiencies will be achieved. On the average, biofilter media becomes saturated to the point it is not effe ctive for VOC control in one (1) to ten (10) years, depending on design. Therefore, testing more than once a year is not

considered vital to ensure VOC control. Please note that a VOC control device, as defined in Proposed Rule 4570, ar e devices that capture air; reduce the VOC content in the air; and release the air into the environment. This would be a system such as an

enclosure vented to a biofilter. It w ould not include control measures, such an increased cleaning, lagoon aerat ors, etc. where air is not captured by the control

measure.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 48 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Staff acknowledges that, at this time, there is not substantial information to determine what constitute minimum testing frequency to ensure compliance with the mitigation measures specified in the rule. However, staff believes that the minimum testing frequency for control devices, as was done for control devices in other District prohibitory rules is twelve (12) months. Al so, as noted in the rule, more frequent testing may initially be necessary to confirm rule compliance. The need for more frequent testing would be determined by the APC O, ARB, and EPA and may only be temporary until the owner/operators has demonstrated that system test ed (e.g. lagoon with a ph between 6.5 and 7.0) is stable.

V. POTENTIAL FUNDING SOURCES

As noted in the cost-effectiveness and socioec onomic analysis, some of these controls have significant costs. However, farms ar e eligible for numerous grants, which could pay for some or all of the costs of implem enting mitigation measures. Some of these

are listed below.

A. National Programs

Environmental Quality Incentive Program (EQIP)

This program provides financial and techni cal assistance to install or implement structural and management c onservation practices. EQIP can be used for manure transport, composters, solid separators, l and application of nutri ents, and many other things. Approximately 60% of the total EQUIP funds are ta rget to projects involving animal agriculture and air quality is one of the four national priorities for this program.

This funding can be used for up to approximatel y 75% of the cost of the project and has a maximum funding per projec t of approximately $450,000. For more information please contact your local or state Natural Resource Conservation (NRCS) office or check their website at http://www.nr cs.usda.gov/programs/eqip/index.html.

EQIP Conservation Innovation Grants Program

This program is intended to accelerate technology transfer and adoption of promising technologies and approaches to address some of the nation's most pressing natural

resource concerns.

This funding can be used for up to approximatel y 50% of the cost of the project. For more information look for the announcement, whic h is usually released in early spring of each year, and the website at http ://www.nrcs.usda.gov/programs/cig/.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 49 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Renewable Energy Systems and Ener gy Efficiency Improvement Program

This program establishes grant, loan, and loan guarantee programs to assist farmers, ranchers, and rural small businesses in purchasing renewable energy systems for making energy efficiency improvements.

The funding can be used for up to approximatel y 25% of the cost of the project. For

more information look for the announc ement or check their website at http://www.rurdev.usda.gov/rbs/farmbill/index.html.

Sustainable Agriculture Resear ch and Education Grants Program

The purpose of this program is to adv ance farming systems that are profitable, environmentally sound, and good for communities.

For more information look for the announcement or ch eck their website at http://www.sare.org/grants/index.htm.

B. State Programs

Please note some of these programs are only available to persons living in certain

areas of the state.

Section 319 Grants

These may fund anaerobic digesters, manur e vacuum devices, solid separators, compost devices and feed management practices. For more information please check their website at http://www. swrc.ca.gov/funding/319h.html

Self Generation Incentive Program

This may fund up anaerobic dige sters. For more informat ion check their website at http://www.sdenergy.org/ContentPage. asp?ContentID=35&SectionID=24.

Energy Efficiency Improvement Loan Fund

This may fund anaerobic digesters. For more information check their website at http://www.safe-bidco.com

VI. PROPOSED RULE 4570 (CONFINED ANIMAL FACILITIES)

The purpose of Proposed Rule 4570 is to lim it VOC emissions fr om confined animal facilities (CAF). Preliminary analysis of t he industries indicate that the cost and feasibility of control options will be highl y variable due to existing infrastructure andSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 50 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 current management practices at the facilities. To provide owner/operators flexibility in complying with the rule's control requirement s, the rule includes several options for compliance and the option for owner/operators to develop their own control measures as appropriate.

A. Summary of Proposed Rule

Section 1.0 Purpose The purpose is to limit volatile organic compound (VOC) emissions from confined animal facilities (CAF).

Section 2.0 Applicability Indicates that the rule applies to any CAF located within the District.

Section 3.0 Definitions Lists general definitions that pertain to the rule.

Section 4.0 Exemptions The rule exempts facilities not exceeding any of the thresholds listed in Table 16 from all requirements except those requiring records be kept demonstrating that they qualify for the exemption.

Table 16: Exemption Thresholds Livestock Category Number of Animals Dairy 1,000 lactating cows Beef Feedlots 3,500 beef cattle Other Cattle Operations 7,500 cows Chickens 650,000 Ducks 650,000 Turkeys 100,000 Swine 3,000 Horses 2,500 Sheep, Goats, or any comb ination of the two 15,000 Any other livestock not listed above 30,000

Section 5.0 Requirements

• Operators of a CAF are to choose a specified number of VOC mitigation

measures from the measures listed in the rule for each emission area on their facility. This cafeteria plan provides flex ibility to facilities considering that CAF facilities vary from one another and not all c ontrols are feasible for all facilities.

Facilities that are unable to use the cont rol options listed to meet the minimum required number of meas ures have the option of developing VOC mitigation measures that are more applicable to their facilities by demonstrating the efficiency of the measures.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 51 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Additionally, facilities have the option of submitting an emission mitigation plan that demonstrates a facility wide VOC reductions of at least 30% in lieu of implementing the minimum required number of measures in the applic able Tables 1 through 6 of the rule. The mitigation measures specifi ed in Tables 1 through 6 of the rule are considered to have been approved by the APCO, ARB, and EPA through the rulemaking process, which provided av enues for such approving authorities to accept the appropriateness of the listed measures. Owners/operators would demonstrate, as part of the emission mitigat ion plan submission, the required facility wide emissions reduction by calculating the control efficiencies of their selected mitigation measures in accordance wit h the procedures/methods shown in Appendix

B of the Final Draft Staff Report for Rule 4570. Any mitigation measure in the emission mitigation plan that is not specif ically listed in the rule is considered an alternative mitigation measure. As such, it is subject to the requirements for alternative mitigation measures, as defined in Section 3.0 of the rule, including the requirement that the mitigation measur e be approved by the ARB, APCO, and EPA. It is important to note that alternate mi tigation measures are evaluated on a case-bycase basis and will only be approved by the APCO, ARB, and EPA if such alternate

measures have been determined to achieve r eductions that are equal to or greater than the reductions that would be achieved by those specific measures listed in the Tables 1 through 6 of the rule.

Additionally, Section 6.1.6 of the rule specifies that t he permit application, including any emission mitigation plan, be publicly noticed with a commenting period of no less than thirty (30) days. During this ti me the ARB, EPA, and stakeholder will have the opportunity to view the emission mitigat ion plan, approve or disapprove of the plan, and recommend changes, as appropriate.

Table 17 Summary of the Minimum Number of VOC Mitigation Measures Per Animal Type and Area Compared to Total Number of Options Area Dairy Beef Other Cattle Swine Poultry

Feed 4 of 8 5 of 8 5 of 8 5 of 12 5 of 10 Silage 1 of 6 1 of 6 1 of 6 0 of 0 0 of 0

Milk Parlor 1of 3 0 of 0 0 of 0 0 of 0 0 of 0 Housing 8 of 26 7 of 15 7 of 23 5 of 10 4 of 17

Solid Manure 2 of 8 1 of 8 1 of 8 1 of 8 1 of 8 Liquid Manure 1 of 11 1 of 11 1 of 11 1 of 11 1 of 11 Land Application 2 of 7 2 of 7 2 of 7 2 of 7 0 of 0

TOTAL 19 of 69 17 of 55 17 of 63 14 of 48 11 of 46

• Suspension of Mitigation Measures This section allows mitigation measures to be suspended in order to promote molting; protect animal health; and addres s quarantine situations. In some limited cases all measures may need to be suspended, such as a case whereSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 52 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 a quarantine prevents equipm ent, animal waste, nonessential personnel, etc. from entering or leaving t he facility. However, the decision to suspend any or all mitigation measures mu st be approved on a case by case basis by the APCO, ARB, and EPA with inpu t from the appropriate experts, such as licensed veterinarians, nutritionists, and government employees. Except for poultry molting, the exemption is desig ned to address atypical, non-periodic, and rare occurrences, not routine situations.

Furthermore, to minimize uncontrolled emissions, facility will have no more than 30 days to address the issue requiri ng the measures to be suspended or implement new mitigation measures to comp ly with rule requirements. This is designed to minimize the time th at any VOC emissions occur in an

uncontrolled manner.

Section 6.0 Permit Requirements

• Owner/operators would need to submit a permit application for each CAF within six (6) months of rule adoption.

• Permit application has to include:

• Contact and legal information;

• List of mitigation measures to be implemented;

• Animal inventory; and

• All information necessary for the Distric t to prepare an emission inventory of all regulated air pollutants emi tted from the facility.

• Owner/operators would need to submit an updat e to the permit application at least once every three (3) years.

• The District would need to act on the pe rmit application within six (6) months of receipt.

Section 7.0 Administrative Requirements

• Recordkeeping

• Indicates recordkeeping requirements

• Compliance testing

• Control devices would need to be init ially source tested upon start-up or modification, and thereafter at least once every 12 months

• Facilities would need to conduct all laboratory testing required to determine compliance

• Test Methods

• Indicates the applicable test methods to be used in determining compliance with the rule requirements.

Section 8.0 Compliance Schedule

• Owners/operators would need to comply with all requirements on and after one year from the permit issuance date.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 53 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 VII. EMISSION REDUCTIONS

Emissions Reduction Analysis

The VOC reductions required by the Extr eme Ozone Plan for Proposed Rule 4570 is 5,767 tons per year (15.8 tons per day) or 25% from the planning baseline of 23,031 tons of VOC per year (63.1 tons per day). District st aff estimated that the VOC reduction from Proposed Rule 4570 is about 7,563 t ons per year (21 tons per day) or 28 percent of the total CAF baseline emission of 27,000 tons per year. The VOC emission reduction analysis is included in Appendix B of the Final Draft Staff Report.

A concern was expressed as why the propos ed rule targets VOC reductions but not

ammonia emissions from CAFs. Ammonia is not a precursor to ozone formation and therefore not the pollutant ta rgeted by the District’s Ozone Plan. Although ammonia is not specifically regulated by Proposed Rule 4570, the VOC mitigation measures of the proposed rule actually have the added air quality benefit of reducing ammonia

emissions. Staff estimated at least 100 tons per day of ammonia reductions could be achieved from the implem entation the proposed VOC mi tigation measures. The ammonia reduction analysis is included in Append ix F of the Final Draft Staff Report.

VIII. HEALTH EFFECTS

Respiratory diseases associ ated with agriculture were o ne of the first-recognized occupational hazards. According to the Institute for Agriculture and Trade Policy (Wallinga 2004), studies at beef, swine, and poultry facilities show increased occurrences of asthma, sinusitis, bronchi tis, decreased lung function, and depression among workers at concentrated animal feeding operations. Of the 331 VOC and gaseous compounds found in odorous samples fr om North Carolina swine facilities, 157 are known airway irritants; chronic irri tation can permanently scar lungs and lead to respiratory problems. (Wallinga 2004)

IX. RULE DEVELOPMENT PROCESS

As part of the rule development process, District staff conducted public scoping meetings in April 2005, public workshops and Socioeconomic Focus Group meeting in March 2006 in order to present, discuss, and solicit comments on Proposed Rule 4570. In addition to the workshops, staff met with representatives of the beef, dairy, poultry, swine industries, and control technology vendor s to receive comments on the technical aspects and compliance costs of the propos ed rule. The comments received from the public, affected sources, California Ai r Resources Board, and United States Environmental Protection Agency during t he public workshop process and technical consultation meetings were incorporat ed into the proposed rule as appropriate.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 54 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Comments received and District responses ar e discussed in Appendix A of the Final Draft Staff Report.

Proposed Rule 4570 and the Fina l Draft Staff Report includi ng the analyses mandated by CH&SC will be published prior to a public hearing on June 15, 2006 for the District Governing Board to consider the adoption of the proposed rule. The notice of the public hearing for this rule project was published in a general circulation newspaper in each of the eight San Joaquin Valley counties, and will be mailed to affected sources and interested parties. The public notice solicited written comments to be submitted by mail, and will identify the name and telephone numbers of the District sta ff that can answer questions and respond to comments. The June 15, 2006 adoption schedule will satisfy the requirement of the CH&SC for the District to adopt a regu lation by July 1, 2006.

X. COST EFFECTIVENESS ANALYSIS

Pursuant to CH&SC 40920.6(a) a cost effectiveness analysis is required to be performed for rules that implement BARCT . For the purpose of calculating the compliance cost and associated cost-effectivene ss of the proposed rule, staff took into consideration those mitigation measures already being implemented at facilities and assumed that owners/operators will likely choose the lowest cost mitigation measures.

This was done to minimize overestimation of compliance costs. A detailed discussion of the analysis is shown in Appendi x C of the Final Draft Staff Report. The estimated cost

effectiveness is as follows:

• Dairies = $4,815 or less per ton of VOC reduced,

• Beef feedlots = $4,505 or less per ton of VOC reduced

• Other cattle facilities= $10,088 or less per ton of VOC reduced, and

• Swine = $3 or less per ton of VOC reduced.

A cost effective analysis was not done fo r poultry because, based on comments from industry and information in the District’s permit database, staff has determined that existing poultry facilities are already required to implement best avail able retrofit control technology. Therefore, the added cost woul d only be recordkeeping costs, which are considered minimal and typically not incl uded in the cost effectiveness analysis.

XI. SOCIOECONOMIC ANALYSIS

Pursuant to CH&SC 40728.5, the District is required to perform a socioeconomic impact analysis prior to the adoption, amendment, or r epeal of a rule that significantly affects air quality or strengthens an emission limit ation. The socioeconomic analysis is presented in Appendix D of t he Final Draft Staff Report.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 55 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 XII. ENVIRONMENTAL IMPACTS

Proposed Rule 4570 underwent an environmental review in accordance with the requirements of the California Environmental Quality Act (CEQA). A proposed negative declaration has been issued by the District and made available for public review. The public commenting period ended on May 29, 2006. Staff received comments on the proposed negative declaration from the St ate Water Resources Control Board and addressed these comments in Appendix A. The initial stud y and proposed negative declaration are presented in A ppendix G of the Final Draft Staff Report. District staff recommends that the District Governing Board approve the negat ive declaration.

XIII. RULE CONSISTENCY ANALYSIS

Pursuant to California Health & Safety Code Section 40727.2, District staff prepared a rule consistency analysis that compares the elements of Propos ed Rule 4570 with the corresponding elements of other District rules, federal r egulations and guidelines that apply to the same source category or type of equipment. The analysis is attached as Appendix E of the Fina l Draft Staff Report.

XIV. REFERENCES

1. APCO BACT Determination and Dairy Permitting Advisory Group material available at http://www.valleyair .org/busind/pto/dpag/dpag_idx.htm.

2. ARB, Staff Report to Consi der Large CAF Definition, May 2005, http://www.arb.ca.gov/r egact/lcaf05/isor.pdf.

3. Archibeque, S.L., Freetl y, H.C., Miller, D.N., Ferrell, C.L. 2005, Feeding High Moisture Corn Instead Of Dry Rolled Corn Reduces Odor Production In Finishing

Beef Cattle Manure Without Sacrifici ng Performance, Proceedings of The Symposium on the State of the Science Animal M anure and Waste Management, January 5-7, 2005, San Antonio, Texas, 2005.

4. Bicudo, J.R. et. al., Managing Manure Solids Dairy Manure Systems: Equipment and Technology, Natural Resource, Agri culture, and Engineering Service NRAES143, Cornell University, 2001, http://www.nraes.org/publications/nraes143.html.

5. California Health and Safety Code 42310, 39011.5, 39023.3, 40724, 40731, 407301, 42301, 44559, et al, http://www.leginfo.ca.gov.

6. Danesh, S.D. et al, Pilot Plant Dem onstration of a Three- Stage Waste Treatment Technology, DGH E ngineering LTD, 2000, http://www.manure.mb.ca/projects/com pleted/pdf/98-01-31-three-stage-wastetreatment.pdf.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 56 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 7. Do, Young et. al., Role of Rhodobacter sp. Strain PS9, a Purple Non-Sulfur Photosynthetic Bacterium Isolated from an Anaerobic Bacteriu m Isolated from an Anaerobic Swine Waste Lagoon in Odor Rem ediation, Applied and Environmental Microbiology, Vol 69(3) 1710-1720, March 2003, http://aem.org/cgi/content/full/69/3/1710.

8. EPA Contract No 68-D6-0111 Task Order 71, Emissions from Animal Feeding Operations, August 15, 2001.

9. Gilley, J.D. et. al., Phototrophic Anaerobic Lagoons as Affected by Copper and Zinc in Swine Diets, Transacti on of the ASAE, 43(6):1853-1859.

10. Haith, D.A., ABEN 476 Solid Waste E ngineering, Agricultural and Biological Engineering Cornell University, Spring 2000, 1999.

11. Hobbs, P.J. et al, Emissions of Volati le Organic Compounds Or iginating from UK Livestock Agriculture, Journal of t he Science of Food and Agriculture, 84:1414- 1420, 2004, http://www.valleyair.org/busind/pto/dpag.

12. Holmes, Robert, CIWMB, e-mail, June 2005.

13. Miner, J.R. et al, Managi ng Livestock Wastes to Preserve Environmental Quality, Iowa State University Press, 2000.

14. Ohio State University, Ohio Livest ock Manure and Wastewater Management Guide Bulletin 604, http://ohioline.os u.edu/b604/b604_15.html.

15. Ritzman, E.G., and F.G. Benedict, Nutr itional Physiology of the Ruminant. Washington, D.C. Carnegie Inst itution of Washington, 1938, http://chla.library.cornell.edu/cgi /t/text/text-idx?c=chla;idno=2892302.

16. Robbins, Janelle, Understanding Alte rnative technologies for Animal Waste treatment, Waterkeepers Alliance, 2004, http://www.waterkeeper.org.

17. SCAQMD support documents fo r Rules 1127 and 1133, on links at http://www.aqmd.gov/rules/support.html.

18. Schmidt, C.E. et. al., Assessment of Reactive Organic Gases and Amines from a Northern California Dairy using the USEPA Surface Emission Isolation Flux Chamber, ARB Research Symposium, 2005, fttp://ftp.arb.ca.gov/carbis/ag/agadvisory/schmidt05jan26.pdf.

19. Wallinga, David, MD, "Concentrated Animal Feeding Operations: Health Risks to Farmers and Workers", Institute for Ag riculture and Trade Policy, October, 2004.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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# APPENDIX A

SIGNIFICANT COMMENT S AND RESPONSES FOR PROPOSED RULE 4570 (CONFI NED ANIMAL FACILITIES)

June 15, 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 58 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 SUMMARY OF SIGNIFICANT COMMENTS AND RESPONSES

California Air Resources Board (ARB): No comments

United States Environmental Protection Agency (EPA) submitted the following

comments:

1. Comment (Rule Section 3.0): The definitions, exem ptions, and mitigation measures should provide measurable and verifiable enforcement criteria and standards, as appropriate. (EPA)

Response : Staff incorporated this as appropriate.

2. Comment (Rule Sections 5.6 through 5.10): Mitigation measures should incorporate maintenance and constr uction characteristics. (EPA)

Response: Staff incorporated this as appropriate.

3. Comment (Sections 5.6 through 5.10): The mitigation measures for lagoon additives and removal of spoiled feed may not be effective and enforceable. (EPA)

Response: These have been removed.

4. Comment (Sections 5.6 through 5.10): Mitigation measures specifying time to implement the measures should al so include the language "as soon as possible, but no later than" and in so me cases the frequency of measures should be increased. (EPA)

Response: Staff believes that wording specifying the maximum period to implement measures is more enforceabl e and the frequency in the rule is appropriate.

5. Comment (Sections 5.6 through 5.10): Explain the use of 80% control efficiency. (EPA)

Response: Staff found biofilters to be the l east expensive of the VOC control

devices. Based on available scientific dat a, the high range of biofilter control efficiency is approximately 80%; theref ore, this was used in the rule.

6. Comment (Sections 7.1 and 7.2): Records should be consistent with the applicable mitigation measures; compli ance monitoring and testing should be frequent enough to endure continued compli ance; demonstrated maintenanceSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 59 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 should be part of t he annual source testing require ments; compliance testing based on disturbances and inputs should be used in addition to periodic testing; and more frequent and comprehensive records may be appropriate. (EPA)

Response: Staff modified the rule as appropriate.

Comments were received from th e following groups and individuals:

AU: Arthur Unger BD: Bill Descary BIO: James Morris and David Mager for BION Environmental Technologies Inc. CAR: J.P. Cativiela for the Community Alliance for Responsible Environmental Stewardship CCA: Tracy Schohr for the Calif ornia Cattlemen's Association CDC: Kevin Abernathy for California Dairy Campaigns

CDF: Steve Shaffer for the California Department of Food and Agriculture CEE: John Shears for Center for Energy Efficiency and Renewable Technologies

CFB: Noelle Cremers for the California Farm Bureau Federation

CH: Carlos Haeussler CM: Jeff Palsgaard for the County of Merced Dept. of Public Health

CRP: Brent Newell for the Center on Race Poverty and the Environment CS: Gary Wegner for CIRCUL8 Systems, Clean By Design

DA: David Avila

EPA: Andrew Steckel for the United St ates Environmental Protection Agency FCF: Karla Kay Edwards for Fresno County Farm Bureau

FF: David Duke for Foster Farms FMM: Carolina Simunovic for Fresno Metro Ministry HR: Jon Tarr for Harris Ranch Feeding Company JH: Chris O'Brien for Jones-Hamilton Company

JP: John Paoluccio MPC: Betsy Hunter fo r Milk Producers Council

PEP: R.L. Matteis for the Pacifi c Egg and Poultry Association

PP: Jennifer Meckel and Randell Is hii for Provost & Prichard RCI: David Lighthall for the Re lational Culture Institute

RK: Ron Kuber RS: Roy Sharp SC: Kristen Hughes for Sustainable Conservation

SMA: Joe Carle for the Sacramento Metropolitan Air Quality Management

District

SWR: John Menke for the State Water Resources Control Board WUD: Paul Martin for Western United DairymenSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 60 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 1. Comment: (Rule Section 3.23) Stakeholders would like to remove the requirement that the permit descripti on include sufficient information to duplicate the measure due to trad e secret concerns. (FCF)

Response: Staff requires sufficient detail, su ch as listed in the rule, in order to develop an emission inventory, as r equired by Senate Bill 700, and to verify compliance. Applicants who would lik e to protect trade secrets from being made available to the general public may request in writing for the District to

treat such information as “confidentia l” pursuant to District Rule 1030 (Confidential Information).

2. Comment (Rule Sections 4.0 and 5.0): Stakeholders would like to update the exemption and rule requirements as new research results are released and to incorporate research that wa s released on the day of the public hearing. (BIO, CAR, CDC, CDFA, CRP, FCF, FMM, HR, MPC)

Response: It is not feasible for staff to fully analyze, review, and incorporate information from preliminary research reports released on the date of the public hearing, while still meeting t he state mandated SIP submitted deadline of July 1, 2006. Industry may req uest rule amendments and the District may amend rules to incorporate new research and technologies. Historically, the District has amended existing rules based on industry’s request when new information becomes available that justif ies changing certain provisions of the

rules.

3. Comment (Rule Section 5.1): Stakeholders question why an authority to construct or a permit to operate is r equired; how the Dist rict can require permits for facilities defined as large CAFs but below the 12.5 tpy threshold when no hearing has be held to require permits; and why the definition of

CAFs is not tied to em ission factors. (CAR)

Response: The District staff held public workshops in March 2006 to present and discuss the provisions of Proposed Ru le 4570. At the workshops, staff presented the reasons for requiring permits for facilities defined as large CAF, regardless of if they were below the 12. 5 tpy threshold. Most importantly, SB700 mandates the District to adopt a rule by July 1, 2006 which includes a provision requiring owners/operators of large CAF to obtain a permit. The large CAF thresholds are consistent with ARB’s large CAF definition. The permitting threshold is based on currently av ailable emission fact ors. As part of the rule development process, a pub lic hearing to adopt the proposed rule is scheduled for June 15, 2006.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 61 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 4. Comment (Rule Sect ion 5.6 to 5.11): Stakeholders believe that the rule does

not fulfill BARCT due to the menu format that allows operat ors to implement less stringent controls. (CRP, FMM)

Response: Staff believes that the least stri ngent controls in the rule are BARCT. More stringent emission contro ls with very high cost effectiveness values for BARCT standards have been included in the rule in order to give credit to facility owners/operator s that choose to go beyond BARCT.

5. Comment (Rule Sect ion 5.6 to 5.11): Stakeholders believe that the rule does not fulfill BARCT or RACT because it only codifies existing practices and prevents emission increases instead of achieving actual reductions. (CRP, FMM)

Response: Staff believes that the least stri ngent controls in the rule are BARCT, a standard beyond RACT. Please see page 22 of the staff report

where it is noted that over 50% of the large confined animal facilities (LCAFs) are not implementing these practices. The 2006 California Department of Food and Agriculture data provided by Mike Francesconi showed a significant

number of dairies are not using these practices. Furthermore, reductions from existing facilities that are using t hese practices were not accounted for in the baseline developed by the District. Therefore, the rule will achieve real

reductions from the emission baseline.

6. Comment (Rule Sect ion 5.6 to 5.11): Stakeholders recommend reduction in the number of mitigation measures r equired. (CAR, CCA, CM, FCF, SC)

Response: The number of required mitigatio n measures is necessary to

ensure the District meets its minimum emission reduction commitment in the Ozone Plan. Additionally, District staf f believes the required measures fulfill

federal Reasonable Availa ble Control Technology (RACT) and state Best

Available Retrofit Control Technology (BARCT) standards.

7. Comment (Rule Section 5.6 to 5.11): Stakeholders recommended additional mitigation measure options and elimination of some mitigation measures. (AU, BIO, CA R, CCA, CDC, CDF, CFB, CRP, DA, FCF, FF, FMM, HR, JH, MPC, RK, SC, WUD)

Response: Staff incorporated these suggestions, as appropriate, based on currently available science.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 62 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 8. Comments (Rule Secti on 5.6 to 5.11): Stakeholders question the feasibility of some of the mitigation measures . (BIO, CAR, CCA, CDC, CDF, FCF, FMM, HR, MPC, RK, SC, WUD)

Response : We agree that not all mitigati on measures are feasible for all facilities. However, they were included to provide opportunity for owners/operators who found t hese measures feasible to implement in their facilities. Some measures may not be f easible for any facilities at this time based on existing infrastructure and cost s, but they may be feasible in the future for new facilities being built or when costs decrease. Therefore, staff included these options in order to a llow flexibility for owners/operators to implement such measures at any time they determine to be feasible and cost

effective.

9. Comment (Rule Sect ion 5.6 to 5.11): Mitigation measures conflict with other rules. (FCF)

Response: Staff reviewed other government agencies’ existing and proposed regulations that apply to CAFs. The R egional Water Quality Board is drafting waste discharge requirements (WDR) for dair ies. Since these will not be finalized prior to Rule 4570 adoption, st aff could not conclusively determine that no conflicts will exist. However, as of 3/26/06, the draft of the waste discharge requirements did not conflict with Rule 4570 requirement s. The differences between the rules are due to the different goals, relevant sci ence available, and jurisdictions of the agencies. Pursuant to state H&SC, staff performed a Rule Consistency Analysis that compares the provisions of Propos ed Rule 4750 with the elements of other District rules, federal rules and regulatio ns, other government agencies’ regulations that apply to the same source category. Please refer to Appendix E of the Final Draft Staff Report for a deta iled discussion of the Rule Consistency Analysis. In addition, Staff contacted David Sholes at the Central Valley Regional Water Quality Board (RWQB) and was told that Proposed Rule 4570 did not conflict with existing RWQB regulations and some of the meas ures were RWQB requirements in some cases. However, In the event that Ru le 4570 requirements are less stringent than required by another agency, owners/operators are oblig ated to comply with the more stringent of the requirements.

10 . Comment (Rule Sect ion 5.6 to 5.11): Will windrow composting be allowed and why is it not a mitigation measure? (CCA)

Response: Facilities have the option of continuing to compost with no changes if they choose mitigation measur es in the rule that do not include composting. Staff was unable to find sufficient information regarding VOC reductions from management practices fo r windrow composting to justify its inclusion in the emission mitigation m easure list. However, facilities may submit it for approval as an al ternative mitigation measure.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 63 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 11. Comment (Rule Section 5.6 to 5.11): Why do the required number of mitigation measures differ by animal type. (CAR, CCA, HR, PP)

Response: Beef, dairy cattle, other cattle, s wine, and poultry are all different animals with slightly different control m easures. The measures available to one type of facility are not always available to other at the same co st—thus the different requirements.

12. Comment (Rule Sect ion 5.6 to 5.11): Why were some options such as probiotics for cattle, microaerobic treatment lagoons, options for use of high moisture feed

other than steamed and hi gh moisture corn not included, and options for using measures in one category to satisfy the requirements of another category not included or deleted. (CCA , CFB, CRP, HR, BIO, WUD)

Response: At the time that t he rule was drafted there was insufficient information

to demonstrate that these would achieve VOC reductions equivalent to or greater

than other measures that an owner/operator could choose and what type of standard (e.g. dosage, frequency, maintenan ce schedule, construction design, etc.) would ensure that these measures achieved such VOC reductions at all times. However, owners/operators may use these measures as alternative mitigation measures after demonstrating th at the measure achieve VOC reductions equal to or greater than other mitigation measures that the owner/operator could choose to comply with rule requirements.

13. Comment (Rule Section 5.6 to 5.11): What happens if only some of the housing units or corrals meet the standard, can cr edit be given towards compliance? (HR, CFB)

Response: The wording of the rule allows different measures to be chosen for each structure (house, corral, pen, freestall) if the owner/operator chooses. Therefore, facility will rece ive credit for each location where a mitigation measure is implement (e.g. if five (5) mitigation measures are required in each corral and two of the five corrals use shade structures meeting the standards, t hen owners/operators would only need to implement an additional four (4) mitigation measures in those two corrals. However, in

the other three corrals with shade structures not meeting the standards the owner/operator would need to implement five (5) mitigation measure, which need not include use of shade structures.)

14. Comment (Rule Sect ion 5.6 to 5.11): Housing animals in an essentially airtight enclosure should not be included. (CAR)

Response: This measure does not require nor does staff expect the enclosure to be airtight. Housing animals in enclosure has been used under researchSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 64 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 conditions and under commercial conditions. Hulls Dairy in Washington has housed their milkers in enclosures for years. This dairy noted that housing animals

in enclosures seemed to be correlated wit h increased milk production, decreased abortions, and decreased calving intervals, thus for their facility it was costeffective. Such benefits have been seen in se veral research studies. Inclusion of mitigation measures does not constitu te endorsements of the processes or guarantees that they are appropriate for all facilities.

15. Comment: Since housing animals in enclosures vented to a secondary control devices has been done, why is it not required.

Response : Based on conversations with David Avil a the cost to retrofit a typical dairy LCAF would be well over $700,000. T hus the cost to retrofit all the dairy

LCAF in the District would exceed the annual net profits of all dairies in the District. Furthermore, there was concern that generation of the electricity needed to ventilate and cool the cow housing woul d cause significant NOx emissions. Finally, the existing enclosed facilities are in states with cooler temperatures and on smaller facilities, therefore staff c an not determine that this method would be

feasible and cost-effective in our distri ct and on dairies with over 1,000 animals. However, the District would like to encourage implementation of new and promising control technologies thus in cluded this measure as an option in Proposed Rule 4570.

16. Comment: Stakeholders believe that the VOC controls should require lagoon covers vented to a control device. (CRP)

Response: Based on information from Roy Sharp and other venders, lagoons vented to a control device will cost over $50 0,000 for the typical dairy. While they may offset the cost with electricity generat ion, there are signifi cant challenges to selling electricity and it is not feasible fo r all facilities. At over $500,000 per facility the cost for each dairy LCAF to implement this would be approximately equivalent the annual profits for all dairies.

17. Comment (Rule Section 5.6 to 5.11): The frequency of measures should be

increased and the allowable times for fac ilities to suspend use of mitigation measures should be decreased. (AU, CRP, FMM)

Response: At the time of the rule develop ment, staff believes that these parameters are appropriate, considering operational limitations on facilities.

18. Comment (Rule Section 5.6 to 5.13): Stakeholders would like to remove the requirement for ARB and EPA approval. (CAR, CDC, CM, FCF)

Response : In order to ensure that the rule is approvable for the state implementation plan, staff believes that such wording is necessary. It isSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 65 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 common wording in District rules, in the past this has not resulted in significant delays of approvals of new technologies or measures.

19. Comment (Rule Section 7.0): Stakeholders believe the rule omits reporting requirements and thus is not enforceable. (CRP)

Response: Please see Section 7.0. Facilities are required to maintain records and will be inspected at leas t once every eighteen months. The inspection will include analysis of t he records to ensure compliance and enforce the requirements of Rule 4570.

20. Comment (Rule Section 7.0): Stakeholders believe that increased cleaning of freestalls will not result in emissions reductions (CRP).

Response : Based on the SCAQMD Rule 1133 technical documents the

VOC reductions from this measure would be at least 50%. This was supported by discussion in the Dairy Permitting Advisory Group (DPAG).
SCAQMD took into account emissions that would occur pr ior to the manure being removed from the housing. Fu rthermore, since the manure is being removed from a relatively VOC uncontrolled area (housing) to a VOC controlled area (storage piles, digeste rs, lagoons, or incorporated into the soil), the VOC are not simply being mo ved from one location to another but are in fact being controlled.

21. Comment (Rule Section 7.1): Stakeholders recommended reducing the recordkeeping requirement to three y ears consistent with the permit review time; expressed concern that reco rdkeeping requirements are burdensome; and would like coordination of reporti ng requirements with other agencies. (CAR, CCA, CDC, CFB, FCF, HR, SC, WUD)

Response: Five years is consistent with ot her District regulations, District permit conditions often require records to be maintained for five (5) years and EPA standards including, but not limited to 40CFR Parts 122 and 412 specify CAF records for water discharge be mainta ined for five years. In order to maintain consistency, staff believes that five (5) years is an appropriate time period and not overly burdensome. Additi onally, many of the records required are already maintained at facilities.

22. Comment (Rule Section 7.1.1.1): Stakeholders question why facilities below

the threshold need to maintain records to demonstrate that they are below the threshold for regulation. (WUD)

Response : This is required in order fo r compliance staff to ensure all facilities subject to the rule are complying; without a recordkeeping requirement for number of animals, it w ould not be possible for a facility toSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 66 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 prove to an inspector that they are exem pt or for the inspector to prove that they are not exempt. Furthermore, the California Health & Safety Code requires the District to obtain sufficient information to calculate an emission inventory. This information is necessary.

23. Comment (Rule Section 7.1.1.2.4) : Stakeholders believe that owners/operators not choosing the option of feeding a ration according to NRC guidelines should not be required to maintain feed records. (WUD)

Response: The California Health and Safety Code 40724.6 requires that this rule mandate that large CAFs submit a permit application that includes all information necessary to determine a VOC emission inventory. Since currently available research suggests that the diet of the animals, specifically excess nutrients in the diet, correlate to increased VOC emissions, the specific diet may be necessary to determine a VOC emi ssion inventory. However, this not required at this time

24. Comment (Rule Section 7.2): Stakeholders recommended clarification on what the source testing requirements appl y to; clarification of test methods required; modification of the monitori ng requirements; and question the test methods. (CAR, CCA, CCC, CDC, CF B, DA, FCF, HR, MPC, SC, WUD)

Response: Staff modified the section to clarify that t he source test requirements only apply to VOC control devices, as defined in Proposed Rule 4570. The monitoring requirements were modified as appropriate. The test methods are approved by the EPA. Spec ific methods are not mandated in all cases in order to allow the owners/oper ators to choose the method most cost effective for their operation.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 67 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 25. Comment (Rule): The rule should address the need to apply the mitigation measures in a manner that protects water quality; contain additional information regarding the potential impact of mitigation measures to water quality; note that other agencies ma y have additional requirements for confined animal facilities; require that the appropriate Regi onal Water Quality Board be notified when implementing meas ures affecting water quality; and require that information requested by the Regional Water be provided. (SWR)

Response: Nothing in the rule waives a facility's responsibility to comply with all applicable requirements of all agencies with ju risdiction or requires use of specific mitigation measures in a manner that would have a negative water impact. On page eight (8) of the Final Draft Staff Repor t staff notes that some measures are not feasible for all facilities due to lim itations and regulations of other agencies including, but not limited to the water board. Since every confined animal facility is unique, even those housing the same type of animal, the potential water impact of mitigation measures will differ by facility. Staff noted on page eight (8) that it is the owners'/operators' responsibility to c hoose the option that makes the most environmental sense for their particular faci lity. Since this rule is limited to minimization of air pollution, staff does not believe that they have the jurisdiction to require owners/operators to notify or provide information to the Regional Water

Board.

26. Comment (Rule): Stakeholders believe that the rule should include ammonia, oxides of nitrogen, and other pollutants. (AU, BIO, CEE, CRP, FMM, PP, RCI, SC)

Response: Rule 4570 is properly limited to VOC regulation. Please see

Section IB of the Final Draft Staf f Report for additio nal information.

27. Comment (Rule): Stakeholders would like to include a fee schedule in Rule 4570. (CAR, CCA, CDC, CFB, FCF, WUD)

Response: The fees are listed in existing District Rule 3010, available at http://www.valleyair.org/rules/currntrules/r3010.pdf.

28. Comment (General): Stakeholder would like an ex tension to the comment deadline. (CRP, SWR)

Response: Due to the tight deadline mandat ed by the Health and Safety Code, staff is unable to accommodate. However, staff will consider the comments submitted after the deadline, as appropriate and as time allows.

29. Comment (Staff Report & Rule): Stakeholders recommended information sources; wording changes; clarification of wording; additional material forSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 68 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 incorporation into the staff repor t; and provided information regarding terminology. (AU, BIO, CAR, CCA, CDC, CDF, CFB, CM, CRP, CS, DA, FCF, FMM, HR, JH, JP, MPC, PEP, PP, RCI, RK, RS, SC, SMA, SWR, WUD)

Response: Staff contacted, reviewed, and incorporated these, as appropriate.

30. Comment (Staff Report Section II & Appendix B & C): The current overall

VOC emission factor for dairies is 19.3 lb/hd/yr of VOC not 21.0 lb/hd/yr of VOC. Therefore, the calculat ions should be changed. (PP, RS)

Response: The Dairy Permitting Advisory Board Report (D PAGR) and initial APCO report (APCOR) on the Dairy Permitti ng Advisory Board's findings in

June of 2005 estimated an emission fact or of 19.3 lb/hd/ yr. However,

additional research has become availabl e since then. As of March 2006, the emission factor for a flush dairy with no freestalls was 19.3 lb/hd/yr, but the

emission factor for a freestall flush dai ry was 21.7 lb/hd/yr. Based on the Conservation Management Prac tices database and CDFA data, approximately 29% of the dairies have no freestalls, therefore the weighed emission factor is 21.0 lb/hd/yr (19.3 x 21% + 21.7 x 79%= 21.0).

31. Comment (Staff Report Section II): In the staff report it states that: "based on CEQA projects, the inventory of dairy cattle in the SJVAB is expected to
increase over 25% in the next three years if all propos ed projects are completed." This appears to be a result of a backlog of permit applications and exceeds previous known growth ra tes for the dairy industry; industry estimates of growth; and CAR's analysi s. For this to occur approximately 425,000 milking cattle would need to be added to the region. Can the District provide supporting information or delete this language? (CAR, FMM)

Response: In the current permit database of applications there are over 425,000 milking cattle proposed. This may be due to a backlog, however the District is expected to act on all of these applications within the next two years. If they were all completed, as noted, the growth would be over 25% in the next three years. This rate of growth is not unheard of. From 2002 to

2005 both Madera and Kern counties had milk ing cow growth rates over 25% according to the USDA/NASS census data. According to the USDA/NASS census data the inventory of milk co ws in the SJVAB increased 6.9% from 2004 to 2005, if this trend cont inued it would result in over 20% growth in the San Joaquin Valley.

32. Comment: Page 34 and 35 of the Final Draft St aff Report states that properly designed and operated lagoons and phototrophic (aerob ic) lagoons emit lessSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 69 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 VOCs that overloaded lagoons, but then stat e that it is beyond BARCT to require owners/operators not to over load their lagoon (CRP).

Response: Please refer to page 34 and 35. Phot otrophic lagoons are not aerobic lagoons, in fact they are anaerobic. Utilizing phototrophic lagoons, lagoons designed according to NRCS recommendations, and not overloading lagoons are not considered beyond BARCT.

Aerobic lagoons require significant electric al input to increase the oxygen content

in the water or more than ten times the land of a typical anaerobic lagoon to ensure natural aeration by providing sufficient su rface area to achieve a minimum of 2.0 mg/L dissolved oxygen content. Based on the cost and impracticality of many existing facilities to build and operate aerobic, staff considered this beyond

BARCT.

33. Comment (Appendix B) : The District did not justify emission reductions. (CRP, FMM)

Response: Emission reductions were based on best engineering judgment; extensive literature review; and comments for technology venders. The calculation

and additional information are available in Appendix B.

34. Comment (Appendix B) : It is unfair to assert that facilities will implement only the lowest cost options. Feedlot operator s have shown good faith to comply with regulations and to go beyond what is legally required. (CCA)

Response: Staff appreciates that facilities go beyond the legal requirements, as noted in the staff report. However, for the cost effectiveness analysis staff traditionally uses the costs of the lowest cost option because this is the cost of rule compliance. Owners/operators who choose to go beyond the lowest cost option

do so for reasons other than t he rule, thus their additional cost and the associated VOC reductions are not solely du e to the rule requirements.

35. Comment (Appendix B): The reduction calculations should be calculated based on how many new mitigation measures are implemented instead of how many animals are subject to the rule to avoi d counting VOC reductions attributable to measures facilities were utilizing before rule adoption. (AU, CRP, FMM)

Response: Since facilities could cease utiliz ation of the measures, and thus VOC reductions at any time if the rule was not in place, staff believes it is appropriate to

calculate emissions based on the number of animals subject to the rule.

36. Comment (Appendix B): Since there are conflicting studies regarding emission

reductions from use of NRC standards based diet or data regarding the number ofSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 70 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 facilities already utilizing this diet, it should not be credited with 10% VOC control efficiency. (CRP)

Response: Ten percent was the lowest control efficiency found in any of the studies, thus in order to be conservati ve staff utilized this value. Based on

conversations with California State Univer sity Fresno researcher Matt Beene, staff

believes that there is insufficient evidence to demonstrate that the facilities tested

in the research used to determine em ission factors fed a diet based on NRC guidelines. Furthermore, staff belie ves that, based on conversations with producers, the majority of facilities do not feed a st rict NRC based diet, instead they tend to modify it for various reas ons to maximize animal health and production

and minimize feed costs.

37. Comment: StakeholderS believe that a 50% control efficiency is applied to all lagoon measures based on the control effici ency for phototrophic lagoons. This is not reasonable. (CRP)

Response: Based on the studies cited on page 34 and 35 of the Final Draft Staff Report the conditions created by des igning lagoons to NRCS standards, not overloading lagoons, or using a solid separator system promote phototrophic lagoons. Phototrophic lagoons are expected to achieve reductions of over 80%,
therefore staff believe the 50% VOC c ontrol efficiency is a conservative and

reasonable estimate.

38. Comment : The control efficiency for tilling and land incorporation of animal waste
should be 0%. Soil does not act si milarly to biofilters. (CRP)

Response : Biofilters are organic media, sim ilar to what is found in fields, particularly those that plow under their crop residue. Fu rthermore several research projects, please see the references in the Final Draft Staff Repor t, show decreased

odor emissions from fields t hat land incorporate manure. Therefore, staff believes

that it is reasonable to cons ider that the soil acts as a biofilter. Although biofilters range in VOC control efficiency from 10% to over 90%, the majority achieve VOC control efficiency of over 80% , therefore staff believes t hat 50% is a conservative estimate of the VOC control efficiency.

39. Comment (Appendix B Table 8): Table 8 in Appendix B does not add to 19.3 lb/hd/yr and should. (PP)

Response: Please see response to Comment 22.

40. Comment: Cost-effectiveness calculations of all control options, including the most expensive should be included in the staff report. (CRP)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 71 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Response: As required by the CH&SC 407 28, the District considered the socioeconomic impacts of this rule and miti gated it to the extent feasible. Please see Appendix C of the Final Draft Staff Report. The lo west cost options result industry-wide costs of over $26 million; equate to over 10 % of the net profit for most of the affected facilities; and is expec ted to result in a loss of approximately 40 jobs. Therefore, the lowest cost opt ions are beyond what typically would be considered for a BARCT rule. Although, co nsidering the significance and quantity of emissions, staff believes this is reasonable for BARCT, but beyond this would

not be.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 72 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 73 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

# APPENDIX B

EMISSION REDUCTION ANALYSIS FOR PROPOSED RULE 4570 (CONFI NED ANIMAL FACILITIES)

June 15, 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 74 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 EMISSION REDUCTION ANALYSIS

I. SUMMARY

This appendix details the estimated emissi on reductions for Proposed Rule 4570.

These estimates are based on the best available information at the time that this report

was written. Table 1 summarizes the result s of the detailed calc ulations, which are

shown later in this section. Based on this data, the rule should generate reductions of approximately 20,919 tons VO C per year (tpy).

Table 1: Summary of Reductions

VOC Emissions

Total CAF Emissions 27,000 tpy (75 tons per day)

Emissions from CAF that are exempt from rule requirements 6,000 tpy (17 tons per day)

VOC Emissions from CAF that are subject to rule requirements 21,000 tpy (58 tons per day)

Reductions from proposed control requirements 7,563 tpy (21 tons per day) or 28% from the total CAF baseline of 27,000 tpy
Reductions required by the

Extreme Ozone Plan 5,767 tpy (15.8 tons per day) or 25% from the planning baseline of 23,000 tpy

* Note some of the values to not add up to each other due to rounding

II. INTRODUCTION

According to USDA records, over 59% of the state's cattl e and 80% of the state's swine population are raised in the San Joaquin Valley Air Basin (SJVAB). A significant number (approximately 42%) of these animals are raised in facilities defined as "large CAF". In contrast, the majori ty of poultry, goats, sheep, and other animals are raised in facilities below the "large CAF" definition. District staff perform ed a preliminary VOC emissions reduction analysis and a prelimin ary cost effectiveness analysis for proposed Rule 4570 (Confined Animal Facilities) bas ed on the information that is currently

available.

The proposed rule would require facilities ab ove the exemption threshold to implement multiple VOC mitigation measures based on the type of animals they raise. The

California Air Resources Board’s definition of a large CAF was us ed as the applicability threshold to satisfy stat e and federal requirements.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 75 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Table 2 Summarizes the Number of Mitigation M easures and Total Number of Options for Each Type of Facility Dairy Beef Other Cattle Swine Poultry

Feed 4 of 8 5 of 8 5 of 8 5 of 12 5 of 10 Silage 1 of 7 1 of 7 1 of 7 0 of 0 0 of 0

Milk

Parlor 1 of 2 0 of 0 0 of 0 0 of 0 0 of 0

Housing 8 of 31 7 of 15 7 of 25 5 of 10 4 of 17

Solid

Manure 2 of 8 1 of 8 1 of 8 1 of 7 1 of 8

Liquid

Manure 1 of 10 1 of 10 1 of 10 1 of 11 1 of 11

Land Applicatio

n 2 of 7 2 of 7 2 of 7 1 of 6 0 of 0

*TOTAL 19 of 69 17 of 55 17 of 63 14 of 48 11 of 46 *Note in Rule 4570 some option in the Rule 4570 tables such as Table 2 Option E1 contains several mitigation measures (meas ures a, b, and c) each one was counted separately for the purpose of calculating t he total mitigation measures in Table 2 of Appendix B.

The selected mitigation measures would be listed in a permit application and would constitute a CAF emission mitigation plan. The permit applications would be approved by the District and subject to District enf orcement. The permit application shall be submitted by December 15, 2006. In accord ance with state law, the emission mitigation measures shall be implement ed within one year after the permit issuance date.

Table 3

Summarizes the Emissions and Reduc tions from Each Animal Type Dairy Beef Other Cattle Swine Poultry Others

Total

Emission

s from

Facilities Subject to

the Rule (lb/yr) 26,951,4

18 1,940,8

07 10,795,230 414,000 1,574,625 0

Percent
Control 36% 36% 42% 72% 0% 0%

Total

Reduction s (lb/yr) 9,594,70

5 698,691 4,533,997 298,080 0 0SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 76 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 III. EMISSION REDUCTION ANALYSIS

A. Background

In performing the analysis, several assumpti ons and abstractions from reality were

made to reflect conservative emissi on reduction results. These include:

• All mitigation measures achieve creditabl e VOC reductions from all facilities that use the mitigation measures. Although staff noted that m any of these are currently being implemented, staff is claiming VOC reduction accomplished by use of mitigation measures listed in this rule regardless of whether or not they were being used prior to rule adoption, unless they were already considered in

the calculation of the baseline emission fa ctor. The reason for this is because, without Rule 4570, the facilities could ceas e use of the mitigation measures at any time. Thus, the rule achieves r eductions by prohibiting the owner/operator from ceasing to use or going below Best Available Retrofit Control Technology (BARCT) for VOC control.

• Facilities will only impl ement the number of mitigat ion measures required by Proposed Rule 4570. Staff acknowledges that industry may do more than is required. Since the additi onal mitigation measures t hat industry implements that go beyond rule requirements can be ceased at any time, thus staff does not believe these reductions are permanent and the direct result of Rule 4570. Therefore, staff does not believe that it is appropria te to claim such reduction or costs in the Rule 4570 development process.

• Facilities will choose the mitigation m easures that are lo west cost BARCT options. Again, staff acknowledges t hat facilities may choose more costly options. Additionally many existing facilit ies already have installed more costly options, which are more effective at reducing VOC emissions. However, as mentioned in the previous bullet owner/ operators could cease using the more costly option at anytime, thus staff does not believe that it is appropriate to claim

reduction achieved in cases where the mo re costly option achieves greater reductions than the less costly option.

• In some cases, no data could be found in the literature search on which to base a control efficiency factor for these practi ces. The District has conservatively
assumed a minimal 10% control effect iveness. As information becomes available, it will be added to this methodol ogy. Additional air quality benefits and control effectiveness for these practi ces would need to be further evaluated through research studies and literature searches.

• Emissions at each source are affected by emission reductions achieved from sources upstream of that source. For example, a mitigation measure for feed that reduces VOC in manure by 10% caus es the emission factor for the lagoon, where the manure is processed, to have 10% less emissions.

• Approximately 29% perc ent of the dairies have no freestalls, based on CDFA data provided by Mike Francesconi.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 77 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 B. Excluded Activities and Facilities

Based on the assumptions above, staff anal yzed the cost effectiveness of least expensive BARCT options t hat owners/operators would lik ely choose to implement.

C. Summary of Emissions and Reductions

Tables 3 through 7 summarize the emission reduction calculations from the control

measures included in the rule. Details of t hose calculations are discussed in Sections D through G.

D. Control Efficiency Calculations for Dairies

The calculations for dairies are based on the following breakdown of the emission factor by source category.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 78 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Table 4: Emissions from Dairy Locations

Emission

Unit Emission

Factors (Freestall

Dairies) Emission Factors (Dairies without Freestalls) Reference

Manure &

Feed in Housing 5.5 lb/hd-yr 4.8 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Enteric

Emissions in Housing 7.6 lb/hd-yr 7.6 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Enteric

Emissions in Milking

Center 0.7 lb/hd-yr 0.7 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Manure

Emissions in Milking

Center 0.2 lb/hd-yr 0.2 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Liquid

Manure Handling 2.7 lb/hd-yr 2.3 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Land Application 5.0 lb/hd-yr 3.7 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

SUBTOTAL 21.7 lb/hd/y 19.3 lb/hd-yr Value used for permitting purposes and emission inventory

calculations

Solid Bedding Storage

Piles 0.2 lb/hd-yr 0.2 lb/hd-yr 1/26/05 Schmidt Flux

Chamber Presentation for ARB Meeting

Feed Piles 0.63 lb/hd-yr 0.63 lb/hd-yr Data submitted to DPAG by Schmidt via ARB. NOTE: this only

considered feed in

feedlanes. It did not

include emissions from

every feed emission

source.

Please note that the values in Table 4 for: manure & feed in housing; enteric emissions in housing; enteric emissions in milking center; manure emissions inSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 79 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 milking center; liquid manure handling; and land application subtotal to the current emission factors for permi tting purposes. Since these values are used for permitting, these (21.7 lb/hd- yr and 19.3 lb/hd-yr) were used in all calculations which applied to the entire facility to avoid overestimating emissions and emission reductions and maintain consistency.

However, the Dairy Permitting Advisory Committee and APCO reports and the permit department noted that not all emission sources were included in these estimates. Two

sources for which emissions were not count ed are the solid beddi ng storage piles and the feed piles outside of the animal housing. Since there is research documenting emission from and VOC control options for thes e sources, staff estimated the emissions from these sources by using data from Schmidt's research. These emission factors are only used for calculating reductions from mitigation measures that control VOC emissions from solid bedding or feed storage piles.

Based on Table 8 and the CDFA data showing that approximately 29% of dairies have no freestalls, staff calculated the weighted averages for emissions for each area on the dairy and the facilities as a w hole by the following equation:

Weighted average= Emission factor for fac ilities with freestalls x 71% + Emission

factor for facilities with no freestalls x 29%

The weighted averages, which staff used to calculate control efficiency of various control measures, are listed in Table 5.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 80 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Table 5: Weighted Emissi ons from Dairy Locations

Emission Unit Emission

Factors (Freestall

Dairies) Emission Factors (Dairies without Freestalls) Weighted Emission

Factors

Manure & Feed in Housing 5.5 lb/hd-yr 4.8 lb/hd-yr 5.3 lb/hd-yr

Enteric

Emissions in Housing 7.6 lb/hd-yr 7.6 lb/hd-yr 7.6 lb/hd-yr

Enteric

Emissions in Milking Center 0.7 lb/hd-yr 0.7 lb/hd-yr 0.7 lb/hd-yr

Manure

Emissions in Milking Center 0.2 lb/hd-yr 0.2 lb/hd-yr 0.2 lb/hd-yr

Liquid Manure Handling 2.7 lb/hd-yr 2.3 lb/hd-yr 2.6 lb/hd-yr

Land Application 5.0 lb/hd-yr 3.7 lb/hd-yr 4.6 lb/hd-yr

SUBTOTAL 21.7 lb/hd/y 19.3 lb/hd-yr 21.0 lb/hd-yr

Solid Bedding Storage Piles 0.2 lb/hd-yr 0.2 lb/hd-yr 0.2 lb/hd-yr

Feed 0.63 lb/hd-yr 0.63 lb/hd-yr 0.63 lb/hd-yr

1. FEED PRACTICES CONTROL MEASURES

Option 1: Feeding according to NRC guidelines

This practice is intended to minimize t he excess nutrients fed to the animals. Based on research suggesting that nitrogen conten t in feed is directly proportional to nitrogen content in manure, staff belie ves that feeding according to the NRC guidelines

, which minimizes excess nutrients in the diet, would reduce VOC emissions. Since there is little data quantif ying this reduction, the 10% default is

assumed. Since it reduces the content of VOC precursors being fed to the animal (entering the animal) it will reduce the VOC precursors ex iting the animal and thus being treated in each animal waste system. It will also reduce the emissions from feed in the housing and stockp iles because there will be le ss VOC precursors in the feed, which could eventually decompose. Therefore, the 10% reduction was applied to the facility wide emission factors. This is expected to be used by all facilities since

reductions in excess nutrient s, such as protein, in feed would not increase costsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 81 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 significantly. Any additionally labor empl oyed to determine what feed formulations would meet NRC guidelines would likely be offset by lower costs for feed due to

lower nutrient content. The reduction calculations are:

Option 1 Reductions = 10%

Option 2: Store grain in a weatherproof storage structure from October through May

This measure is intended to reduce excess mo isture. Since the microorganisms that degrade organic material to form VOCs require moisture, this is expected to reduce

the VOC emissions from the fe ed storage. Since there is little data quantifying this reduction, the 10% default is assumed. Howe ver, it only affects the emissions from feed and these emissions were already reduced by 10% due to implementing an

NRCS diet. The reduction calculations are:

Option 2 Reductions = 0.63 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 10% (control efficiency from Option 2) = 0.06 lb/hd-yr

This is out of an emission factor of 21.0 lb/hd-yr.

The percent reductions = 0.06 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.3%

Option 3 and 4: Two mitigation measur es for cleaning feed from housing

These measures are intended to minimize mo isture, surface area for VOCs to move

from the feed to the atmo sphere, and anaerobic digestio n due to wet conditions and thick depths of animal waste. Data sugges ts that these practices would minimize VOC emissions, however there are no peer-rev iewed articles that quantify this. Therefore, staff assu med a default reduction of 10% for each measure. However, it only affects the emissions from feed and t hese emissions were already reduced by Option 1 and Option 2.

Option 3 Reductions = 0.63 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 10% (contro l efficiency) = 0.05 lb/hd-yr

Option 4 Reductions = 0.63 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 90% (emissions re maining after implementing Option 3) x 10% (control efficiency) = 0.05 lb/hd-yr

The total reductions from Option 3 and 4= 0. 05 lb/hd-yr (Option 3) + 0.05 lb/hd-yr (Option 4) = 0.10 lb/hd-yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 82 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 This is out of an emission factor of 21.0 lb/hd-yr.

The percent reductions = 0.10 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.5%

2. SILAGE PRACTICES

Option 5: Silage practices

These measures are intended to minimize mo isture, surface area for VOCs to move

from the feed to the atmo sphere, anaerobic digestion due to wet conditions, and excess nutrients in animal waste due to silage practices. Data suggests that these practices would minimize VOC emissi ons, however there are no peer-reviewed articles that quantify this. Therefore, st aff assumed a default reduction of 10% for each measure. However, it only affe cts the emissions fr om feed and these emissions were already reduced by Option 1.

Option 5 Reductions = 0.63 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 10% (control efficiency) = 0.06 lb/hd-yr

This is out of an emission factor of 21.0 lb/hd-yr.

The percent reductions = 0.06 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.3%

3. MILK PARLOR PRACTICES

Option 6: Flush/clean milk parlor after each milking

In the studies used to calcul ate the emission factor this practice was being done. Therefore, the baseline assume s that all facilities implement this practice. Thus, no reduction from the baseline is anticipated. This measure was included to ensure all current and future facilities implement practices accounted for in the baseline

emission estimate.

4. FREESTALL PRACTICES

Options 7 and 8: Vacuum or scrape freesta lls after each milking or flush more frequently than milking and rake, harrow, scr ape, or grade bedding at least once every two weeks

Typically, facilities flush once per m ilking or scrape once a day (once every two milkings). Typically, facilities cle an to bedding no more than once a month. By cleaning twice as frequently you cut the time manure is in the freestalls by half. Therefore you reduce the emissions is the fr eestalls by 50%. The freestall emissionsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 83 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 are approximately 97% of the total emissions from manure and feed in the housing (3% of the emissions are in the corrals). The reduction calculations are:

Freestall emission = 5.3 lb/hd-yr x 97% (emissions from freestalls)

= 5.14 lb/hd-yr from freestalls.

Options 7 and 8 Reductions = 5.14 x 90% (e missions remaining after implementing Option 1) x 98% (emissions remaining after implementing Option 3 and 4) x 50% (control efficiency)= 2.3 lb/hd-yr

This is out of an emission factor of 21.7 lb /hd-yr, but only affects 71% of the facilities (facilities with freestalls).

The percent reductions = 2.3 lb/hd-yr ÷ 21.7 lb/hd-yr x 71% = 8%

5. CORRAL PRACTICES

Option 9, 10, 11, 12, 13, and 14: All housing measures to clean corals, manage manure depth, and minimize moisture

These are intended to minimize moistu re and anaerobic digestion due to wet conditions or thick depths of manure that prevents the manure from drying completely and oxygen continuing to come in contact with all animal waste in the pens and corrals. Data suggests that this would minimize VOC emissions, however there are no peer-reviewed articles that quant ify this. Therefore, staff assumed a
default reduction of 10% for each measure. The corrals account for approximately
3% of the emissions from the animal housing. The reduction per measure is:

Corral emissions = 5.3 lb/hd-yr x 3% (emissions from corrals) =0.16 lb/hd-yr from corrals

Option 9 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 10% (control efficiency)= 0.01 lb/hd-yr

Option 10 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 9) x 10% (control efficiency)= 0.01 lb/hd-yr

Option 11 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after im plementing Option 9) x 90% (emissions remaining after implementing Option 10) x 10% (control efficiency)= 0.01 lb/hd-yr

Option 12 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after im plementing Option 9) x 90% (emissionsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 84 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 remaining after implementing Option 10) x 90% (emissions remaining after implementing Option 11) x 10% (cont rol efficiency)= 0.01 lb/hd-yr

Option 13 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after im plementing Option 9) x 90% (emissions remaining after implementing Option 10) x 90% (emissions remaining after implementing Option 11) x 90% (emissions re maining after implementing Option 12) x 10% (control efficiency)= 0.01 lb/hd-yr

Option 14 Reductions= 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after im plementing Option 9) x 90% (emissions remaining after implementing Option 10) x 90% (emissions remaining after implementing Option 11) x 90% (emissions re maining after implementing Option 12) x 90% (emissions remaining after im plementing Option 13) x 10% (control efficiency)= 0.01 lb/hd-yr

Options 9 through 14 Reduction = 0.01 lb/hd-yr (Option 9) + 0.01 lb /hd-yr (Option 10) + 0.01 lb/hd-yr (Option 11) + 0.01 lb/hd-yr (Opt ion 12) + 0.01 lb/hd- yr (Option 13) + 0.01 lb/hd-yr (Option 14) = 0.06 lb/hd-yr

This is out of an emission factor of 21.0 lb/hd-yr.

The percent reductions = 0.06 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.3%

6. SOLID MANURE/SEPARATED SOLIDS PRACTICES

Options 15 and 16: Cover piles outside the pens

These measures are intended to minimize moisture and anaerobic digestion due to wet conditions. There is no data regardi ng the amount of emissions from the manure storage piles, therefor e staff conservatively estimated the separated solids and the manure piles emit approx imately the same amount of VOC. Since there is little data regarding reductions staff assu med a default reduction of 10% for each mitigation measure. The reduction per measure is:

Option 16 Reductions = 0.2 lb/hd-yr (p iles) x 90% (emissions remaining after implementing Option 1) x 10% = 0.02 lb/hd-yr reductions.

Option 17 Reductions = 0.2 lb/hd-yr (p iles) x 90% (emissions remaining after implementing Option 1) x 10% = 0.02 lb/hd-yr reductions.

Option 16 and 17 Reductions = 0.02 lb/hd-yr + 0.02 lb/hd-yr = 0.04 lb/hd-yr

This is out of an emission factor of 21.0 lb/hd-yr.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix B: VOC Emission Reductions June 15, 2006

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- 85 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 The percent reductions = 0.04 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.2%

7. LIQUID MANURE PRACTICES

Option 17: All of the lagoon control options

AEM, 3/03, Vol 69, pg 1710-1720, indica tes a 80-93% decrease in emissions from swine phototrophic lagoons; ILOC, 1995, pg 80-85, DiSpirito, found the same in swine lagoons; and JFB, 70:39-44, Hiraishi, found the same in sewage wastewater lagoons. The loading rate contributing to a phototrophic are typically found in lagoons utilizing a solid separator, NRCS guidelines for anaerobic lagoon design, and microaerobic nutrient management. However, these studies were for swine and not cattle. Based on AP42 by E PA, swine emit 63.5% of the volatile solids that cattle do. Therefore, in order to be conservati ve, staff assumed that cattle lagoons are 63.5% as efficient as swine lagoons ( 63.5% x 80% = 50%). The baseline is 2.3 lb/hr/yr, however there are fewer em issions due to the use of the NRC feed guidelines. The reduction per measure is:

Option 17 Reductions = 2.6 lb/hd-yr x 90% (emissions remaining after implementing Option 1) x 50% (control efficiency) = 1.17 lb/hd-yr

This is out of a total emissi on factor of 21.0 lb/hd-yr.

The percent reductions = is 1.17 lb/hd-yr 21.0 lb/hd-yr = 6%.

8. LAND APPLICATION PRACTICES

Option 18 & 19: All methods for crop application.

These practices are intended to rapidly land incorporate the manure or waste water. The soil is expected to act as a biofilter since it is an organic media with significant microbial populations and airflow. Resear ch suggests biofilters range in efficiency from 10% to 90% depending on how they ar e maintained. Conservatively staff
assumed 50% control. The baseline emissi ons from crop application are 4.6 lb/hdyr. The reduction per measure is:

Options 18 & 19 Reductions = 4.6 lb/ hd/year x 90% (emissions remaining after implementing Option 1) x 50% (contro l efficiency) = 2.07 lb/hd-yr

This is out of a total emissi on factor of 21.0 lb/hd-yr.

The percent reductions = is 2.07 lb/hd-yr 21.0 lb/hd-yr = 10%.

9. TOTAL REDUCTIONSSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix B: VOC Emission Reductions June 15, 2006

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- 86 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 The total percent reductions can be calc ulated by summing the percent reductions for each mitigation measure above.

Total Reductions = 36%

E. Beef Feedlot Control Efficiencies

Emissions from liquid manur e handling was excluded because it is not expected that there are existing beef feedlot s subject to Proposed Rule 4570 that use a liquid manure handling system or will continue to use a liquid manure handling system after rule adoption. The expected emission sources are manure and enteric emissions in the pens, feed emissions, solid manure handling em issions, and land application emissions.

Based on American Society of Agricultural and Biological Engineers (ASAE) Publication D384.1, manure from beef cattl e in confinement (adult and growing cattle) contains 68%

the amount of volatile solids as that of a mature dairy cow (lactating and dry cattle).

Since the amount of volatile solids in the ma nure is a function of diet and the amount of manure, emission factors for dairy cattle in T able 8 were multiplied by 0.68 to estimate

the emissions for beef cattle and are shown in Table 9. These factors were used to

calculate the control factors for beef feedlot control measures.

Table 6: Emissions from Beef Cattle

Emission Unit VOC Emission Factor
Manure & Feed in Housing 3.3 lb/hd-yr

Enteric Emissions in Housing 5.2 lb/hd-yr

Land Application 2.5 lb/hd-yr

Subtotal 11.0

Feed 0.43 lb/hd-yr
Solid Storage Piles 0.1 lb/hd-yr

Please note that these number s in Table 8 for: manure & feed in housing; enteric emissions in housing; enteric emissions in milking center; manure emissions in milking center; liquid manure handling; and land application subtot al to approximately the current emission factors for permitting purposes of 11.1 lb/hd-yr. The slight difference in Table 9 is due to uncertainty in the emi ssions from each animal unit, but the numbers

are based on the best available science. Si nce the 11.1 lb/hd-yr factor was used for permitting, this was used in all calculations th at applied to the entire facility or emission inventory to maintain consistency.

However, the 11.1 lb/hd-yr does not include all emission sources. Two sources for

which emissions were not counted are the solid bedding storage piles and the feedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 87 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 piles outside of the animal housing. Since there is research documenting emissions from and VOC control options fo r these sources, staff estimated the emissions from these sources by using data from Schmidt's research for dairy cattle, adjusted to be applic able to beef cattle based on manure volatile solid

content. These emission factors for feed and solid storage pile are only used for the purpose of calculating reductions from mitigation measures that control VOC emissions from solid bedding or feed storage piles.

1. FEED PRACTICES

Option 1: Feeding according to NRC guidelines

This practice is intended to minimize t he excess nutrients fed to the animals. Based on research suggesting that nitrogen cont ent in feed in dire ctly proportional to nitrogen content in manure, staff belie ves that feeding according to the NRC guidelines, that minimize excess nutrients in the diet, will reduce VOC emissions. Since there is little data quantifying this reduction, the 10% default is assumed. Since it reduces the content of VOC precur sors being fed to the animal (entering the animal) it will reduce the VOC precursor ex iting the animal and thus being treated in each animal waste system. It will also r educe the emissions from feed in the housing because there will be less VOC precursors in the feed, which could eventually decompose. Theref ore, the 10% reduction was appl ied to the facility wide

emission factor. The reduc tion calculations are:

Option 1 Reductions = 10%

Option 2: Store grain in a weatherproof storage structure from October through May

This measure is intended to reduce excess mo isture. Since the microorganisms that degrade organic material to form VOCs require moisture, this is expected to reduce

the VOC emissions from the fe ed storage. Since there is little data quantifying this reduction, the 10% default is assumed. Howe ver, it only affects the emissions from feed and these emissions were already reduced by 10% due to implementing an

NRCS diet. The reduction calculations are:

Option 2 Reductions = 0.43 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 10% (control efficiency from Option 2) = 0.04 lb/hd-yr

This is out of an emission factor of 11.1 lb/hd-yr.

The percent reductions 0.04 lb/hd-yr ÷ 11.1 lb/hd-yr = 0.3%SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 88 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Option 3, 4, and 5: Three mitigation measures for cleaning feed from housing

These measures are intended to minimize mo isture, surface area for VOCs to move

from the feed to the atmo sphere, anaerobic digestion due to wet conditions, and

excess nutrients emitted in the manure due to feeding practices. Data suggests that these practices would minimize VOC emissions, however there are no peerreviewed articles that quantify this. Theref ore, staff assumed a default reduction of 10% for each measure. However, it onl y affects the emissions from feed and these emissions were already reduced by Option 1 and Option 2.

Option 3 Reductions = 0.43 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 10% (contro l efficiency) = 0.103 lb/hd-yr

Option 4 Reductions = 0.43 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 90% (emissions remaining after implementing Option 3) 10% (control efficiency) = 0.03 lb/hd-yr

Option 5 Reductions = 0.43 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 90% (emissions remaining after implementing Option 3) 10% (control efficiency) = 0.03 lb/hd-yr

Option 3, 4, and 5 Reductions = 0.03 lb/hd-yr (Option 3) + 0.03 lb/ hd-yr (Option 4) + 0.03 lb/hd-yr (Option 5) = 0.09 lb/hd-yr

This is out of an emission factor of 11.1 lb/hd-yr.

The percent reductions= 0.09 lb/hd-yr ÷ 11.1 lb/hd-yr = 0.8%

2. SILAGE PRACTICES

Option 6: Silage Practices

These measures are intended to minimize mo isture, surface area for VOCs to move

from the feed to the atmo sphere, anaerobic digestion due to wet conditions, and

excess nutrients emitted in the manure due to feeding practices. Data suggests that these practices would minimize VOC em issions, however there are no peerreviewed articles that quantify this. Ther efore, staff assumed a default reduction of 10% for each measure. However, it onl y affects the emissions from feed and these emissions were already reduced by Option 1.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 89 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Reductions Option 6= 0.43 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 10% (control efficiency) = 0.04 lb/hd-yr

This is out of an emission factor of 11.1 lb/hd-yr.

The percent reductions 0.43 lb/hd-yr ÷ 11.1 lb/hd-yr = 0.3%

3. HOUSING PRACTICES

Option 7, 8, 9, 10, 11, 12, and 13: All housing measures to clean corals, manage manure depth, and minimize moisture

These are intended to minimize moistu re and anaerobic digestion due to wet conditions or thick depths of manure that prevents the manure from drying completely and oxygen continuing to come in contact with all animal waste in the pens and corrals. Data suggests that this would minimize VOC emissions, however there are no peer-reviewed articles that quant ify this. Therefore, staff assumed a
default reduction of 10% for each measur e. The reduction per measure is:

Option 7 Reductions= 3.3 x 90% (emissions re maining after implementing Option 1) x 10% (control efficiency)= 0.30 lb/hd-yr

Option 8 Reductions= 3.3 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implement ing Option 7) x 10% (control efficiency)= 0.27 lb/hd-yr

Option 9 Reductions= 3.3 x 90% (emissions re maining after implementing Option 1) x 90% (emissions remaining after implementing Option 7) x 90% (emissions remaining after implementing Option 8) x 10% (control efficiency)= 0.24 lb/hd-yr

Option 10 Reductions= 3.3 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 7) x 90% (emissions remaining after implementing Option 8) x 90% (emissions remaining after implementing Option 9) x 10% (cont rol efficiency)= 0.22 lb/hd-yr

Option 11 Reductions= 3.3 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 7) x 90% (emissions remaining after implementing Option 8) x 90% (emissions remaining after implementing Option 9) x 90% (emissions re maining after implementing Option 10) x 10% (control efficiency)= 0.19 lb/hd-yr

Option 12 Reductions= 3.3 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 7) x 90% (emissions remaining after implementing Option 8) x 90% (emissions remaining after implementing Option 9) x 90% (emissions re maining after implementing Option 10) xSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 90 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 90% (emissions remaining after implementi ng Option 11) x 10% (control efficiency)= 0.18 lb/hd-yr

Option 13 Reductions= 3.3 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 7) x 90% (emissions remaining after implementing Option 8) x 90% (emissions remaining after implementing Option 9) x 90% (emissions re maining after implementing Option 10) x 90% (emissions remaining after impl ementing Option 11) x 90% (emissions remaining after implementing Option 12) x 10% (control efficiency)= 0.16 lb/hd-yr

The total reductions from Options 7 thr ough 13 = 0.30 lb/hd-yr (Option 7) + 0.27 lb/hd-yr (Option 8) + 0.24 lb/ hd-yr (Option 9) + 0.22 lb/hd- yr (Option 10) + 0.19 lb/hdyr (Option 11) + 0.18 lb/hd-yr (Option 12) + 0.16 lb/hd-yr (Option 13)= 1.56 lb/hd-yr

This is out of an emission factor of 11.1 lb/hd-yr.

The percent reductions 1.56 lb/hd-yr ÷ 11.1 lb/hd-yr = 14%

4. SOLID MANURE/SEPARATED SOLIDS PRACTICES

Options 14: Cover piles outside the pens

These measures are intended to minimize moisture and anaerobic digestion due to wet conditions. There is no data regardi ng the amount of emissions from the manure storage piles, therefor e staff conservatively estimated the separated solids and the manure piles emit appr oximately the same amount of VOC. Since there is little data regarding reductions staff assu med a default reduction of 10% for each

measure. The reduc tion per measure is:

Option 14 Reductions = 0.1 lb/hd-yr (p iles) x 90% (emissions remaining after implementing Option 1) x 10% = 0.01 lb/hd-yr reductions.

This is out of a total emissi on factor of 11.1 lb/hd-yr.

The percent reduction from covering each type of piles= is 0.01b/hd/yr 11.1 d/yr =
0.1%

5. LAND APPLICATION PRACTICES

Option 15 & 16: All methods for crop application.

These practices are intended to rapidly land incorporate the manure or waste water. The soil is expected to act as a biofilter , since both biofilter s and soil are organic media with significant microbial populat ions and airflow. Research suggests biofilters range in efficiency from 10% to 90% depending on how they areSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 91 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 maintained. Conservatively staff assumed 50% control. The baseline emission from crop application is 2.5 lb/hd-yr. The seven mo isture minimization practices utilized as mitigation measures for animal housing means there is less moisture in the manure and therefore thus less potential for VOC emissions. There is also less potential

VOC emissions due to the us e of a NRC diet thus the baseline emissions should also be reduced by 10%, the control efficiency of using a diet based on the NRC guidelines. The reduction per measure is:

Options 15 & 16 Reductions = 2.5 lb/hd/ year x 90% (emissions remaining after implementing Option 1) x 50% (contro l efficiency) = 1.13 lb/hd-yr

This is out of a total emissi on factor of 11.1 lb/hd-yr.

The percent reductions is = is 1.13 lb/hd-yr  11.1 lb/hd-yr = 10%.

6. TOTAL REDUCTIONS

The total percent reductions can be calc ulated by summing the percent reductions for each mitigation measure above.

Total Reductions = 36%

F. Other Cattle Control Efficiencies

A significant number of these animals ar e being raised for replacement animals on dairies, as veal, or as stock for beef feedlot s. There is limited scientific data for this source. Therefore, since these animals are not producing milk and are closer in age to beef cattle than lactating cows , the control efficiencies of mitigation measures are

assumed identical to that of beef cattle. In cases where there is no similar control measure for beef cattle, the control efficienc y for the most similar dairy mitigation

measure was utilized.

1. REDUCTIONS

Option 1: Feed to NRC Guidelines

Option 1 Reduction = 10% from beef data

Option 2: Store grain in a weatherproof storage structure from October through May

Option 2 Reduction = 0.3% from beef data

Option 3, 4, and 5: Three mitigation measures for cleaning feed from housingSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 92 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Option 3, 4, and 5 Reduction = 0.8% from beef data

Option 6: Silage Practices

Option 6 Reduction = 0.3% from beef data

Option 7, 8, 9, 10, 11, 12, and 13: A ll housing measures to clean housing, manage manure depth, and minimize moisture

Option 7, 8, 9, 10, 11, 12, and 13 Reduction = 14% from beef data

Options 14: Cover piles outside the pens

Option 14 Reduction = 0.1% from beef data

Option 15: All of the lagoon control options

Option 15 Reductions = 6% from dairy data

Option 16 and 17: All methods for crop application.

Option 16 and 17 = 10% from dairy data

2. TOTAL REDUCTIONS

The total percent reductions can be calc ulated by summing the percent reductions for each mitigation measure above.

Total Reductions = 42%

G. Swine Control Efficiencies

The emission factor listed in ARB's most recent emission documents is 4.6 lb/hd-yr.

Based on the US EPA 2001 cited in the staff r eport 2.4 lb/hd-yr of emissions are from lagoons. Therefore, 4.6-2.4= 2.2 lb/hd-yr are fr om feed, housing, and land application. Since there is little data quantifying the c ontribution of each, it is assumed that approximately 50% of the em issions are from land application and 50% are from feed and housing. Additionally, 50% of the emissions from feed and housing are being

attributable to feed and the ot her 50% are being attributable to manure. Currently, there

are no swine facilities above the rule threshol d that stockpile manure or utilize a dry manure handling system. Therefor e, these options will not be considered in this analysis.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 93 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 1. FEED PRACTICES

Option 1: Feeding according to NRC guidelines

This practice is intended to minimize t he excess nutrients fed to the animals. Based on research suggesting that nitrogen and protei n content in feed is directly related to VOC emissions from manure, staff belie ves that feeding according to the NRC guidelines, which minimizes excess nutri ents in the diet, would reduce VOC

emissions. Since there is little data conclu sively quantifying this reduction, the 10%

default is assumed. Since it reduces the VOC precursors in t he animal excretions and the feed itself, staff applies the 10% reduction to the facility wide emission

factor. The reduction calculations are:

Option 1 Reductions = 10%

Option 2: Store grain in a weatherproof storage structure from October through May

This measure is intended to reduce excess mo isture. Since the microorganisms that degrade organic material to form VOCs require moisture, this is expected to reduce

the VOC emissions from the fe ed storage. Since there is little data quantifying this reduction, the 10% default is assumed. Howe ver, it only affects the emissions from feed and these emissions were already reduced by 10% due to implementing an

NRCS diet. The reduction calculations are:

Option 2 Reductions = 0.55 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 10% (control efficiency from Option 2) = 0.05 lb/hd-yr

This is out of an emission factor of 4.6 lb/hd-yr.

The percent reductions 0.05 lb/hd-yr ÷ 4.6 lb/hd-yr = 1%

Option 3, 4, and 5: Three mitigation measures for cleaning feed from housing

These measures are intended to minimize mo isture, surface area for VOCs to move

from the feed to the atmo sphere, anaerobic digestion due to wet conditions, and

excess nutrients emitted in the manure due to feeding practices. Data suggests that these practices would minimize VOC emissions, however there are no peerreviewed articles that quantify this. Theref ore, staff assumed a default reduction of 10% for each measure. However, it onl y affects the emissions from feed and these emissions were already reduced by Option 1 and Option 2.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 94 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Option 3 Reductions = 0.55 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 10% (contro l efficiency) = 0.04 lb/hd-yr

Option 4 Reductions = 0.55 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 90% (emissions re maining after implementing Option 3) x 10% (control efficiency) = 0.04 lb/hd-yr

Option 5 Reductions = 0.55 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 90% (emissions re maining after implementing Option 3) x 10% (control efficiency) = 0.04 lb/hd-yr

The total reductions from Option 3, 4, and 5= 0.04 lb/hd-yr (Option 3) + 0.04 lb/hd-yr (Option 4) + 0.04 lb/hd-yr (Option 5) = 0.12 lb/hd-yr

This is out of an emission factor of 4.6 lb/hd-yr.

The percent reductions= 0.12 lb/hd-yr ÷ 4.6 lb/hd-yr = 3%

2. HOUSING PRACTICES

Options 6, 7, 8, 9, and 10: All housi ng measures to clean housing, manage manure depth, and minimize moisture

These are intended to minimize moistu re and anaerobic digestion due to wet conditions or thick depths of manure that prevents the manure from drying completely and oxygen continuing to come in contact with all animal waste in the pens and corrals. Data suggests that this would minimize VOC emissions, however there are no peer-reviewed articles that quant ify this. Therefore, staff assumed a
default reduction of 10% for each measur e. The reduction per measure is:

Option 6 Reductions = 2.2 lb/hd-yr (e missions from animal housing) x 90% (emissions remaining after Option 1) x 10% (control efficiency) = 0.20 lb/hd-yr

Option 7 Reductions = 2.2 lb/hd-yr (e missions from animal housing) x 90% (emissions remaining after Option 1) x 90% (emissions remaining after Option 6 x 10% (control efficiency) = 0.18 lb/hd-yr

Option 8 Reductions = 2.2 lb/hd-yr (e missions from animal housing) x 90% (emissions remaining after Option 1) x 90% (emissions remainin g after Option 6) x 90% (emissions remaining after Option 7) x 10% (control efficiency) = 0.16 lb/hd-yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 95 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Option 9 Reductions = 2.2 lb/hd-yr (e missions from animal housing) x 90% (emissions remaining after Option 1) x 90% (emissions remainin g after Option 6) x 90% (emissions remaining after Option 7) x 90% (emissions rema ining after Option 8) x 10% (control efficiency) = 0.14 lb/hd-yr

Option 10 Reductions = 2.2 lb/hd-yr (e missions from animal housing) x 90% (emissions remaining after Option 1) x 90% (emissions remaining after Option 6) x 90% (emissions remaining after Option 7) x 90% (emissions rema ining after Option 8) x 90% (emissions remaining after Option 9) x 10% (control efficiency) = 0.13 lb/hd-yr

The total reductions from Options 6, 7, 8, 9, and 10 = 0.20 lb/hd-yr (Option 6) + 0.18 lb/hd-yr (Option 7) + 0.16 lb /hd-yr (Option 8) + 0.14 lb/ hd-yr (Option 9) + 0.13 lb/hdyr (Option 10) = 0.81 lb/hd-yr

This is out of an emission factor of 4.6 lb/hd-yr.

The percent reductions = 0.81 lb/hd-yr ÷ 4.6 lb/hd-yr = 18%

3. LIQUID MANURE PRACTICES

Option 11: Maintain specif ic organic loading rates.

AEM, 3/03, Vol 69, pg 1710-1720, indicates a 80-93% decrease in emissions from swine phototrophic lagoons; ILOC, 1995, pg 80-85, DiSpirito, found the same in swine lagoons; and JFB, 70:39-44, Hiraishi, found the same in sewage wastewater lagoons. The loading rates found in photot rophic lagoons are typically found in lagoons utilizing a solid separator, NRCS guidelines for anaerobic lagoon design, and microaerobic nutrient management. The basel ine is 2.4 lb/hr/yr, however there

are fewer emissions due to use of the NRC feed guidelines and manure management that affected this source. The reduction per measure is:

Option 11 Reductions = 2.4 lb/hd-yr x 0% (emissions remaining after implementing Option 1) x 80% (control efficiency) = 1.73 lb/hd-yr

This is out of a total emissi on factor of 4.6 lb/hd-yr.

The percent reduction for lagoons= is 1. 73 lb/hd-yr 4.6 lb/hd-yr = 38%.

4. LAND APPLICATION PRACTICES

Option 12 & 13: All methods for crop application.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix B: VOC Emission Reductions June 15, 2006

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- 96 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 These practices are intended to rapidly l and incorporate the m anure or wastewater. The soil is expected to act as a biofilter since it is an organic media with significant microbial populations and airflow. Resear ch suggests biofilters range in efficiency from 10% to 90% depending on how they ar e maintained. Conservatively staff
assumed 50% control. The baseline emission from crop application is 1.1 lb/hd-yr. The moisture minimization practices ut ilized as mitigation measures for animal housing means there is less moisture in th e manure and therefore thus less potential for VOC emissions. There is also less pot ential VOC emissions due to the use of a

NRC diet thus the baseline emissions shou ld also be reduced by 10%, the control efficiency of using a diet based on the NRC guidelines The reduction per measure is:

Option 12 & 13 Reductions = 1.1 lb/hd/y ear x 90% (emissions remaining after implementing Option 1) x 20% (emissions re maining after implementing Option 11) x 50% (control efficiency) = 0.10 lb/hd-yr

This is out of a total emissi on factor of 4.6 lb/hd-yr.

The percent reductions is = is 0.10 lb/hd-yr 

 4.6 lb/hd-yr = 2%.

5. TOTAL REDUCTIONS

The total percent reductions can be calc ulated by summing the percent reductions for each mitigation measure above.

Total Reductions = 72%SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix C: Cost Effect iveness Analysis June 15, 2006

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- 97 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

# APPENDIX C

COST EFFECTIVENESS ANALYSIS FOR PROPOSED RULE 4570 (CONFI NED ANIMAL FACILITIES)

June 15, 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 98 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 COSTS AND COST EFFE CTIVENESS ANALYSIS

I. SUMMARY

Proposed Rule 4570 (Confined Animal Facilit ies) would require owner/operators of confined animal facilities (CAF) to reduce VOC emissions from CAF. As presented in Appendix B of this Staff R eport, annual VOC emissions from CAF are estimated to be over 27,000 tons per year (t py). Draft VOC control requirements would require owner/operators to implement various mitigati on measures, based on the type of facility. These mitigation measures are already used by many facilities in the San Joaquin Valley, but not all of the practi ces are used on all of the facilitie s. In fact, most facilities do not use all of the measures. This repor t presented the expected additional costs for existing facilities to implement additional co ntrols not already being used, in order to comply with the required number of controls listed in Rule 4570.

The cost effectiveness of the proposed rule was analyzed for four main CAF categories

and the results are as follows:

• Dairies = $4,815 per ton of VOC reduced

• Beef feedlots = $4,505 per ton of VOC reduced,

• Other cattle facilities, not included in the dairy or beef feedlot category = $10,088 per ton of VOC reduced, and

• Swine = $3 per t on of VOC reduced.

Cost effective analysis was not done for poultry because, based on comments from industry and information in the District’s permit database, staff has determined that existing poultry facilities are already required to implement best avail able retrofit control technology. Therefore, the added cost woul d only be recordkeeping costs, which are considered minimal and typically not incl uded in the cost effectiveness analysis.

II. REQUIREMENTS OF ANALYSIS

The California Health and Safety Code 40 920.6(a) requires the San Joaquin Valley

Unified Air Pollution Control District to conduct both an absolute cost effectiveness analysis and an incremental cost effectivene ss analysis of available emission control options before adopting each Best Available Retrofit Control Technology (BARCT) rule. The purpose of conducting a cost effectiv eness analysis is to evaluate the economic reasonableness of the pollution control measur e or rule. The analysis also serves as a guideline in developing the contro l requirements of a rule.

Absolute cost effectiveness of a control option is the added annual compliance cost in dollars per year divided by the emission reduction achieved in tons VOC reduced perSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix C: Cost Effect iveness Analysis June 15, 2006

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- 99 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 year. This report presents t he District staff's analysis of the absolute cost effectiveness of Proposed Rule 4570.

Incremental cost effectiveness is intended to measure the change in costs, in dollars per year, and emissions reductions, in t ons of VOC reduced per year, between two progressively more effective control opti ons or technologies. Incremental cost effectiveness compares the differences in costs and the differences in emissions reductions of the two candidate control opt ions. Incremental cost effectiveness does not reveal the emission reduction potential of the control options, merely the additional cost of adding the next most effective contro l to a given control measure. Unlike the absolute cost effective analys is that identifies the cont rol option with the greatest emission reduction, incremental cost effe ctiveness does not present a meaningful

correlation between emissions reductions and cost effectiveness. Therefore, the relative values produced in the incremental cost effectiveness analysis and the absolute cost effectiveness values are not compar able and cannot be evaluated using similar

standards.

Rule 4570 would provide CAF operators with the flexibility to comply with the VOC control requirements by choosing the requi red minimum number mitigation measures from a list of multiple meas ures or developing mitigation measures of their own not specified in the rule provided they could dem onstrate that such measures could achieve equal or greater reductions than those identified in the rule. However, prior approval by the APCO, ARB, and EPA would need to be grant ed for such alternative mitigation measures. In general, since owners/operators have the flexibility to choose from a list of mitigation measures, staff believes owner s/operators will likely choose the option with the best cost effectiveness for his/her parti cular operation. As a result, only the absolute cost effectiveness is presented.

III. SOURCES OF COST DATA

District staff used available cost information contained in technical reports, provided by control equipment vendors, and received from stakeholders, to conduct a preliminary cost effectiveness analysis of the proposed requirements of Rule 4570. Staff refined the cost effectiveness analysis presented at the socio-economic focus group due to information provided by the California Depar tment of Food and Agriculture, industry representatives, and venders.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix C: Cost Effect iveness Analysis June 15, 2006

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- 100 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 IV. COST EFFECTIVENESS ESTIMATES

A. Dairy CAF

1. Feed mitigation measures a. Feed according to National Research Council (NRC) guidelines No significant cost because the facilities typically already employ the services of animal nutrition specialists that can dete rmine what dietary changes, if any, are needed. Changes, if any, would result in feeding animals less excess nutrients thus potentially lower feed costs due to less protein cost in the feed. COST = $0.00 b. Store grain in a weatherproof storage structure from October through May. Based on industry and CDFA comments, staff be lieves most if not all large facilities already have their grain in such structures. COST = $0.00 c. Feed cleaning practices Many facilities already implem ent these practices. Typically facilities use these practices approximately half as much as required by the rule. Based on Michigan State University Cares data an average of an additional 1.37 hrs labor per 150 cows would be required every two w eeks and $3.30 per hour maintenance and operating costs for equipment. Staff assu med a labor rate of $9.50 per house

based on the US Bureau of Labor Statistics for skilled agricultural labor. Staff assumed an additional $9.50 for benefits and a ssociated costs. Therefore the cost

is: COST = [$3.30 per hour (equipment) + $19.00 (labor)] x 1.37 hrs x 26 times per year (number of two week periods in one year) ÷ 150 animals = $5.30 per cow per year

2. Silage practices a. Cover silage piles Cost, based on industry comments, is approxim ately $10 per cow per year. However, based on CDFA data over 90% already use one of the silage control options in

Rule 4570 Table 2 Section B. COST = $10 per cow x 10% (adj ustment factor considering only 10% of facilities will implement this method) = $1 per cow per year

3. Milk parlor practices

a. Flush This is already implemented by most facilitie s for animal health or ensuring a higher milk grade. Thus, there is no additional cost. COST = $0.00 4. Housing practices

a. Clean animal waste from the housing. Assume similar cost to the mitigation measur e for cleaning feed from freestalls of $5.30 per cow per year. However, based on CDFA data only 71% have freestalls.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix C: Cost Effect iveness Analysis June 15, 2006

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- 101 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 COST = $5.30 per cow x 71% (adjus tment factor considering only 71% of facilities will implement th is method) = $3.76 per cow per

year 5. Corral practices a. Clean and manage corrals Comments from industry suggested that the cost of cleaning and maintaining corrals would be approx imately eight times that of cleaning freestalls. However, based on permit database information, 90% of the fac ilities would already comply. COST = 8 x $5.30 x 10%= $4.24 per cow per year 6. Solid manure practices

a. Cover animal waste Cost is approximately $1.00 per ton covered. Based on ASAE D 384, dairy cattle excrete approximately 20 lb/day. COST = 20 lb/day x 365 days ÷ 2,000 lb/ton x $1.00 per ton = $3.65 per cow per year 7. Liquid manure practices a. Use solid separator Based on permit database data the majority, if not all facilities use a settling basin, mechanical separator, or other measure. Therefore, t he cost is considered not significant. COST = $ 0.00 8. Land application practices a. Dry solid manure or only apply liqu id manure at a rate at which it

will be absorbed into the soil. T hese measure affecting the timing of land application, but do not require significant additional labor or require owners/operators to implement new activities. COST = $0.00 per cow per year.

The total additional cost to implement new controls is approximately $18 per head per year. From Appendix B the total reductions are approxim ately 42% of the emission

factor of 21.0 lb/hd/ yr. Therefore the co st effectiveness is: Cost effectiveness = $18 ÷ (35.6% x 21 lb/hd/yr) x 2000 lb/ton =$4,815 per ton of VOC

reduced.

B. Beef CAF

1. Feed mitigation measures a. Feed according to National Research Council (NRC) guidelines No significant cost because the facilities typically already employ the services of animal nutrition specialists that can dete rmine what dietary changes, if any, are needed. Changes, if any, would result in feeding animals less excess nutrients thus potentially lower feed costs due to less protein cost in the feed. COST = $0.00SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 102 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 b. Store grain in a weatherproof storage structure from October through May. Based on industry and CDFA comments, staff be lieves most if not all large facilities already have their grain in such structures. COST = $0.00 c. Feed cleaning practices Many facilities already implem ent these practices. Typically facilities use these practices approximately half as much as required by the rule. Based on Michigan State University Cares data an average of an additional 1.37 hrs labor per 150 cows would be required every two w eeks and $3.30 per hour maintenance and operating costs for equipment. Staff assu med a labor rate of $9.50 per house

based on the US Bureau of Labor Statistics for skilled agricultural labor. Staff assumed an additional $9.50 for benefits and a ssociated costs. Therefore the cost

is: COST = [$3.30 per hour (equipment) + $19.00 (labor)] x 1.37 hrs x 26 times per year (number of two week periods in one year) ÷ 150 animals = $5.30 per cow per year

2. Silage practices Not feed silage. Increase feed costs may be balanced by decreased finishing times thus the cost is expected to be negligible. COST = $0.00 3. Housing practices b. Clean and manage corrals Comments from industry suggested that the cost of cleaning and maintaining corrals would be approximately $42.40 per head per year for dairy cattle. Since the beef corrals are cleaned 1/13 th the number of times as dairy, the cost is expected to be 1/13 th the cost for dairy cattle. COST = $42.40 ÷ 13 = $3.26 per head per year 9. Solid manure practices

a. Minimal cost since it would onl y set a new time schedule for land applying the manure, it would not r equire additional land application or handling practices. COST = $0.00 10. Liquid manure practices a. Facilities already comply thus no cost. COST = $0.00 11. Land application practices b. Dry solid manure or only apply liqu id manure at a rate at which it

will be absorbed into the soil. Thes e measure affecting the timing of land application, but do not require significant additional labor or require owners/operators to implement new activities. COST = $0.00 per cow per year.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix C: Cost Effect iveness Analysis June 15, 2006

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- 103 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 The total additional cost to implement new c ontrols is approximately $9 per hd per year. From Appendix B the total reduc tions are approximately 42% of the emission factor of 11.1 lb/hd/yr. Therefore t he cost effectiveness is: Cost effectiveness = $9.00 ÷ (36% x 11.1 lb/hd/yr) x 2000 lb/ton =$4,505 per ton of VOC

reduced.

C. Other Cattle CAF

1. Feed mitigation measures a. Feed according to National Research Council (NRC) guidelines No significant cost because the facilities typically already employ the services of animal nutrition specialists that can dete rmine what dietary changes, if any, are needed. Changes, if any, would result in feeding animals less excess nutrients thus potentially lower feed costs due to less protein cost in the feed. COST = $0.00 b. Store grain in a weatherproof storage structure from October through May. Based on industry and CDFA comments, staff be lieves most if not all large facilities already have their grain in such structures. COST = $0.00 c. Feed cleaning practices Many facilities already implem ent these practices. Typically facilities use these practices approximately half as much as required by the rule. Based on Michigan State University Cares data an average of an additional 1.37 hrs labor per 150 cows would be required every two wee ks and $3.30 per hour maintenance and operating costs for equipment. Staff assu med a labor rate of $9.50 per house

based on the US Bureau of Labor Statistics for skilled agricultural labor. Staff assumed an additional $9.50 for benefits and a ssociated costs. Therefore the cost

is: COST = [$3.30 per hour (equipment) + $19.00 (labor)] x 1.37 hrs x 26 times per year (number of two week periods in one year) ÷ 150 animals = $5.30 per cow per year

2. Silage practices a. Cover silage piles Cost, based on industry comments, is approxim ately $10 per cow per year. However, based on CDFA data over 90% already use one of the silage control options in

Rule 4570 Table 2 Section B. COST = $10 per cow x 10% (adj ustment factor considering only 10% of facilities will implement this method) = $1 per cow per year

3. Housing practices

a. Clean animal waste from the housing. Assume similar cost to the mitigation measur e for cleaning feed from freestalls of $5.30 per cow per year. However, based on CDFA data only 71% have freestalls.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix C: Cost Effect iveness Analysis June 15, 2006

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- 104 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 COST = $5.30 per cow x 71% (adjus tment factor considering only 71% of facilities will implement th is method) = $3.76 per cow per

year 4. Corral practices a. Clean and manage corrals Comments from industry suggested that the cost of cleaning and maintaining corrals would be approximately eight times that of cleaning freestalls. However, based on permit database information, 90% of the fac ilities would already comply. COST = 8 x $5.30 x 10%= $4.24 per cow per year 5. Solid manure practices

a. Cover animal waste Cost is approximately $1.00 per ton covere d. Based on ASAE D 384 calves excrete approximately 3.2 lb/day and heifers excrete approximately 8.2 lb/day. COST = (8.2 lb/day + 3.2 lb/hd/yr) ÷ 2 x 365 days ÷ 2,000 lb/ton x $1.00 per ton = $1.04

per cow per year

6. Liquid manure practices a. Use solid separator Based on permit database data the majority, if not all facilities use a settling basin, mechanical separator, or other measure. Therefore, t he cost is considered not significant. COST = $ 0.00 7. Land application practices a. Dry solid manure or only apply liqu id manure at a rate at which it

will be absorbed into the soil. Thes e measure affecting the timing of land application, but do not require significant additional labor or require owners/operators to implement new activities. COST = $0.00 per cow per year.

The total additional cost to implement new controls is approximately $15 per hd per year. From Appendix B the total reducti ons are approximately 42% of the emission factor of 7.08 lb/hd/yr. Theref ore the cost effectiveness is: Cost effectiveness = $15 ÷ (42% x 7.08 lb/hd/yr) x 2000 lb/ton =$10,088 per ton of VOC

reduced.

D. Swine CAF

Staff believes that there is only one existing swine op eration that exceeds the applicability threshold for Draft Rule 4570. Based on discussions with the swine CAF staff and a tour of the facility , staff believes that the fac ility will comply with Draft Rule 4570 requirements with few significant operat ional or physical changes. Based on current practices, the facility is expected to choose the following mi tigation options from

the draft rule:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix C: Cost Effect iveness Analysis June 15, 2006

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- 105 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 1. Feed and silage practices: a. Feed according to National Research Council (NRC) guidelines: No significant cost because the faci lity indicated that they already employ the services of animal nutrition specialists that can determine what dietary changes, if any, are needed. Changes, if any, would result in feeding anim als less excess nutrients thus potentially lower feed costs due to less protein cost in the feed. COST = $0.00 b. Store grain in a weat herproof storage structure. The facility already implements this, thus no cost COST = $0.00

c. Remove uneaten wet feed from the housing after rain events Since the housing is roof ed with drainage outside of the housing and the floors are slatted with daily flushing of the pits underneath the sl ats, staff believes that the facility already complies with this mitigation measure. COST = $0.00 d. Remove spilled feed from the fac ility at least once every fourteen days. The feed is transported in a closed system from the grain st orage systems to the housing. Thus, staff would not expect significant spilled feed outside of the housing. The floor of the housing is slatted with daily flushing of the pit underneath the housing. Staff would expec t spilled feed, within fourteen days,

to fall between the slats and be remov ed from the housing during the daily flushings. COST = $0.00 e. Feed or dispose of rations within forty-eight (48) hours of grinding and mixing ratios. The facility grinds and mixes its own ra tios in a nearby granary. Currently, depending on animal size, grain is placed in the silos at least once a week, in some cases more frequent. Therefore, the added cost would be minimal. The total vehicles serving the facility would not change, however instead of completely filling the silos, they would only partially fill silos. Therefore, vehicles would be at each silo, but overall t here would be no additional trips. Any additional costs for grinding more fr equently could be mitigated by decreased need for vehicles, since fewer vehicles would be serving the facility on a given day. COST = $0.00 2. Housing practices a. Clean animal waste at least twice a day The facility already implements this measure. COST = $0.00 b. Manage pens such that the ani mal waste depth does not exceed eight (18) inches. The facility already implements this measure.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 106 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 COST = $0.00

c. Ensure that water from tr oughs and drinkers do not spill onto earthen ground. The facility already implements this measure. COST = $0.00 d. Inspect water pipes and troughs and repair leaks at least once a day. The facility already has staff entering the animal housing on a regular basis,

thus there would be minimal cost for in specting pipes daily. There would be no added cost for repairing pipes since they would need to be repaired eventually; the rule only ensures that they are repaired in a rapid manner. Assuming a wage of $9.50 per hour (wage fo r a skilled agriculture worker listed in the US Bureau of Labor Statistics) wit h benefits and associated costs of $9.50 per hour we have a total cost of $19.00 per hour. Assume an additional minute to look at the pipes per house per day. Thus the cost is: COST = $9.50 x 1 minute/hous e x 8 houses x 365 days/yr ÷ 60 minutes/hr = $462 per year. e. Use a slatted floor system The facility already implements this measure. COST = $0.00 3. Solid waste practices a. The facility does not handle solid waste COST = $0.00 4. Liquid waste practices a. Based on industry comments the organic loading is less than 3.5 mg/mL thus would comply with rule requirements. COST = $0.00 5. Land application practices a. Based on industry comments, ther e is no solid waste land-applied and the liquid waste is anaerobically digested in their lagoon before land application. COST = $0.00 The total additional cost to implement new controls is approximately $462 per year. From Appendix B the total reductions are appr oximately 298,080 lbs/ yr (149 tons per year). Therefore the cost effectiveness is: Cost effectiveness = $462 ÷ 149 tons per year =$3.10 per ton of VOC reduced.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioeconomic Impact Analysis June 15, 2006

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- 107 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

# APPENDIX D

SOCIOECONOMIC ANALYSIS FOR PROPOSED RULE 4570 (CONFI NED ANIMAL FACILITIES)

June 15, 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 108 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 109 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

## Socioeconomic Analysis Proposed RULE 4570:

CONFINED ANIMALS FACILITIES

4 MAY 2006

Prepared for

San Joaquin Valley Unified Air Pollution Control District 1990 E. Gettysburg Avenue
Fresno, CA 93726

Prepared by

Applied Development Economics 2029 University Avenue • Berkeley, California 94704 • (510) 548-5912 1029 J Street, Suite 310 • Sacramen to, California 95814 • (916) 441-0323

www.adeusa.comSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

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- 110 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

## CONTENTS

1. Executive Summary .......................................................................... 112

2. Introduction ....................................................................................... 114

3. Description Of Draft Rule 4570..................................................... 115

4. Methodology...................................................................................... 116

5. Impacted Industries Subject To New Rule 4570 (Confined Animal Facilities)............................................................................................ 118

5.1 Regional Demographic And Economic Trends .................. 118

5.2 General Inflation Trends......................................................... 121

5.3 Description Of Affected Industries....................................... 122

5.4 Net Profit Ratios ...................................................................... 134

5.5 Economic Characteristics Of Affected Sources .................. 134

6. Socioeconomic Impacts ................................................................... 137

6.1 Compliance Cost Estimates.................................................... 137

6.2 Business Responses To Compliance Costs .......................... 137

6.3 Impacts On Affected Industries ............................................ 138

6.4 Impact On Small Businesses .................................................. 140

Appendix A ............................................................................................ 141



## FIGURES

1 San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) Air Basin .................................................................. 114

2 United States Bureau of Labor Statistics: Consumer Price Index (US Urban Wages), 1994-2004....................................................... 122

A United States Bureau of Labor Statistics: Consumer Price Index (US Urban Wages), 1994-2004....................................................... 141


## Tables

1. Total Annual Compliance Cost for CAFs...................................1

2 Population Growth: San Joaquin Valley Region, 1994 - 2004 ... 119

3 Employment Profile Of The San Joaquin Valley Region 1999 –

2004...................................................................................................... 121SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 111 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 4 Milk and Cheese Trends: United States and Top twenty Leading

Exporters1994-2004 ($2004)............................................................ 124

5 Cattle Export Trends: United States and Top Twenty Leading

Exporters 1994-2004 ($2004)........................................................... 124

6 Chicken Industry Export Trends: United States and Top Twenty

Leading Exporters 1994-2004 ($2004) ........................................... 125

7 Swine Industry Export Trends: United States and Tope Twenty

Leading Global Exporters 1994-2004 ($2004) .............................. 125

8 Dairy Industry Trends: United States, 1994-2004........................ 127

9 Cattle Industry Trends: United States, 1994-2004....................... 127

10 Unit Price of Cattle, 1994-2 004 ($2004)..................................... 128

11 Trends in Broilers: United States 1994-2004 ($2004)................. 128

12 Swine Trends: United States, 1994-2004 ($2004)........................ 129

13 Dairy Industry Trends: San Joaquin Valley Region and State of

California, 1994-2004 ($2004).......................................................... 131

14 Cattle and Calves Industry Trends: Beef Cattle Only: San Joaquin

Valley Region and State of Calif ornia 1994-2004 ($2004).......... 131

15 Cattle and Calves Industry Trends: All Other Cattle: San Joaquin

Valley Region and State of Calif ornia 1994-2004 ($2004).......... 132

16 Swine Industry Trends: All Other Cattle: San Joaquin Valley

Region and State of California 1994-2004 ($2004)...................... 132

17 Poultry and Eggs Industry Trends: San Joaquin Valley Region

and State of California, 1994-2004.................................................. 133

18 Net Profit Ratios: Dun and Bradstreet 1992-2002 ..................... 134

19 Dairy Industry Profile: San Joaquin Valley Region and the State,

2004..................................................................................................... . 136

20 Cattle Industry Profile: San Joaquin Valley Region and the State,

2004..................................................................................................... . 136

21 Swine Industry Profile: San Joaquin Valley Region and the State,

2004...................................................................................................... 136

22 Socioeconomic Impact Analysis: Annual Cost of Compliance 137

23. Socioeconomic Impact Analysis Rule 4570: Net Profits. .....34

24 Socioeconomic Impact Analysis Rule 4570: Impact on Net

Profits.. 138

25 Socioeconomic Impact Analysis: Rule 4570.............................. . 139SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 112 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

## 1. EXECUTIVE SUMMARY

The San Joaquin Valley Unified Air Pollution Control District (“District”) seeks to adopt Draft Rule 4570 to meet certain United States Environmental Protection Agency (US EPA) mandates and timelines with regards to improved air quality in the region. This section of the report summarizes the findings of the socioeconomic analysis of Rule 4570. Large CAFs subject to Draft Rule 4570 generate an estimated $4.5 billion per year in revenues, from which $249.6 million in net profit is earned annually . The analysis indicates that, although there are approximately 524 large confined animal facilities (CAFs) that will be subject to the rule, there are only approximately 247 of the 524 total large CAFs subject to Draft Rule 4570 that would need to implement additional mitigation measures in Draft Ru le 4570 to comply with rule requirements. The table below summarizes the number and type of CAFs that would need to implement additional mitigation measures to comply with the rule and its estimated annual compliance costs.

TABLE 1 Summary of Estimated Total Annual Compliance Cost for CAFs that Would Need to Implement Addi tional Mitigation Measures

Type of CAF Number of CAFs Estim

+ated Total Annual Compliance Costs Dairy 233 $18,324,074
Beef Feedlots 6 $590,112

Other Cattle Facilities 5 $7,147,266
Swine 3 $540
TOTAL 247 $26,061,922

Source: District and stakeholder comments

The socioeconomic impact analysis shows that the total annual compliance costs represents <1 percent of the net profits for large CAF swine stak eholders; 9.6 percent of the net profits of large CAF dairy stakeholders; 13.0 percent of the net prof its of large cattle stakeholders (beef feedlots); and 13.5 percent of the net profits of other large CAF cattle stakeholders. Annual compliance costs associated with the District’s costs for impacted other cattle industries exceed the threshold of significance, resulting in direct employment impacts of approximately 17 jobs. Factoring in indirect impacts associated with the direct loss of 17 jobs, the rule could result in the loss of an additional 23 jobs across different industries, for a total job im pact of 40 jobs, which represents less than one percent of all jobs in the cattle industry in the region.

However, the expected costs of the rule are primar ily labor costs (e.g. labor for increased cleaning; inspection for leaks; covering of manure piles; and covering of silage piles). Therefore, the ruleSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 113 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 requirements are expected to create additional jobs. Based on Minnesota and Kansas State University data, the rule requirements will result in the following:

• At least 0.17 hrs/yr/cow for cleaning of ho using at affected facilities, on the average (considering approximately 29% of cows on dairies are at facilities without freestalls)

• At least 0.03 hrs/yr/cow for covering solid ma nure, feed, and silage at affected facilities, on the average (considering some facilities do not store manure onsite and some facilities do not use silage)

• Total hours = at least 0.20 hrs/yr/cow at affected facilities, on the average

• Total full time jobs (job gains)= at least 150 positions 1 This does not take into consideration any job loses caused by rule costs.

Additionally, several of the measures may have the added benefit of improving animal health (e.g. measures reducing ammonia emissions may reduce respiratory health ailments and measures minimizing manure-based bedding may reduce calving intervals.) The analysis also examines whether small busi nesses are disproportionately impacted by the draft rule and concludes that these sources are not disproportionately impacted.

1 [(1,878,720 dairy cows at large CAFs x 233 large dairy CAFs that will need to implement practices ÷ 430 large dairy CAFs) + (174,848 beef cattle at large CAFs x 6 larg e beef feedlots that will need to implement practices ÷ 16 large beef feedlots) + (1,524,750 other cattle at large CAFs x 5 large other cattle CAFs that will need to implement practices ÷ 16 large other cattle CAFs)] x 0.20 hours per head ÷ 40 hours per week ÷ 52 weeks per year = 150 full time equivalentsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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## 2. INTRODUCTION

This report describes the socioec onomic impacts of Draft Rule 4570 (Confined Animal Facilities). Following this introduction, the report summarizes the proposed rule and describes the methodology for the socioeconomic analysis. In Section 5, the report describes the

economic characteristics of sources affected by Draft Rule 4570. The sixth section analyzes the socioec onomic impacts of compliance costs on the affected sources and the regional economy. This report is based on the version of Draft Rule 4570 that was published on March 13, 2006 in preparation for the board hearing June 15, 2006.

The report is prepared pursuant to the provisions of AB2051 (Section 40728.5 of the California Health and Safety Code), which requires an assessment of socioeconomic impacts of proposed air quality rules. The findings in this report can assist District staff in understanding the socioeconomic impacts of Draft Rule 4570, and can assist staff in preparing a refined version of the rule. A final draft report will be published prior to a public hearing on June 15, 2006 for the District Governing Board to consider the adoption of the proposed rule. Figure 1 is a map of the eight-county region that comprises the San Joaquin Valley Air Basin. As indicated in the map, Kern County is not completely within the District.

FIGURE 1 San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) Air BasinSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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## 3. DESCRIPTION OF DRAFT RULE 4570

The San Joaquin Valley Unified Air Pollution Control District’s (District) 2004 Extreme Ozone Atta inment Plan and the 2002 and 2005 Rate and Progress Plan (ROP) identify the need to address

VOC emissions from confined anim al facilities in the San Joaquin Valley Air Basin (SJVAB). Annual VOC emissions from confined animal facilities (CAF) are estimated to be over 27,000 tons. Draft Rule 4570 (Confined Animal Facilities) would require owners and operators of confined animal facilities to reduce VOC emissions by implementing various mitigation measures based on the type of facility.

Draft Rule 4570 would provide CAF operators with the flexibility to comply with the VOC control requirements by choosing any mitigation measures from a list of multiple measures, or by implementing alternative mitigation measures provided such alternative measures achieve equivalent emissions reductions as those listed in the rule and provided the alternative measures have been approved by the District. District staff indicate that the draft rule should result in a limited number of dairies (233 dairies out of a total of 1,500 in the region), cattle facilit ies (11 facilities out of a total of 5,290 in the region) and swine animal facilities (1 to 3 out of a total of 313 in the region) implementing additional mitigation measures not already used on the facility. In all likelihood, only one swine facility will be subject to the rule, but to conservatively estimate the compliance cost, staff assumed all three swine facilities would be subject to the rule. District staff issued a report that discusses, in detail, the costs resulting from the mitigations that affected stakeholders may likely implement to comply with Draft Rule 4570, and this report is called “Appendix C: Cost Effectiveness Analysis for

Rule 4570.”SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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## 4. METHODOLOGY

The socioeconomic analysis involves the use of information provided directly by affected sources, as well as secondary data used to describe the industries affected by the proposed provisions of Draft Rule 4570. The approach is briefly described below. Applied Development Economics (ADE) began the analysis by preparing a statistical description of the industry groups of which the affected sources are a part, and by analyzing data on the number of jobs, sales levels, the typical profit ratios, and other economic indicators for each industry.

This report relies heavily on the most current data available from a variety of sources, such as the 2002 Agricultural Census, 1997 Agricultural Census, Minnesota IMPLAN Group, and the State of California’s Employment Devel opment Department (EDD) Labor

Market Information Division. Global trends data is available from the United Nations Food and Agri culture Organization (UN FAO). For purposes of estimating profits, ADE relied on Dun and Bradstreet and the United States Department of Agriculture (USDA).

With the above information, ADE was able to estimate net after tax profit ratios for sources affected by the draft rule. ADE calculated ratios of profit per dollar of revenue for affected industries. The

result of the socioeconomic anal ysis shows what proportion of profits the compliance costs repres ent. Based on assumed thresholds of significance, ADE discusses in the report whether the affected sources are likely to reduce jobs as a means of recouping the cost of rule compliance or as a result of reducing business operations. To the extent that such job losses appear likely, the indirect multiplier effectsof the job losses are estimated using a regional IMPLAN inputoutput model. When analyzing the socioeconomic impacts of proposed new rules and amendments, ADE works closely within the parameters of accepted methodologies discussed in a 1995 California Air Resources Board report called “Development of a Methodology to Assess the Economic Impact Required by SB513/AB969” (by Peter Berck, PhD, UC Berkeley Department of Agricultural and Resources Economics, Contract No. 93-314, August , 1995). The author of this report reviewed a methodology to assess the impact that California Environmental Protection Agency proposed regulations would have on the ability of California businesses to compete. The California Air Resources Board (ARB) has inco rporated the methodologiesSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 117 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 described in this report in its own assessment of socioeconomic impacts of rules generated by ARB. One methodology relates to determining a level above or below which a rule and its associated costs is deemed to have signific ant impacts. When analyzing the degree to which its rules are significant or insignificant, ARB employs a threshold of significance that ADE follows. Berck reviewed the threshold in his analysis and wrote, “The Air Resources Board’s (ARB) use of a 10 percent change in [Return on Equity] ROE (i.e. a change in ROE from 10 percen t to a ROE of 9 percent) as a threshold for a finding of no sign ificant, adverse impact on either competitiveness or jobs seems reas onable or even conservative.”SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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## 5 . IMPACTED INDUSTRIES SUBJECT TO NEW RULE 4570 (CONFINED ANIMAL FACILITIES)

This section of the socioeconomic analysis describes demographic and economic trends in the San Joaquin Valley region. Subsection 5.1 compares the demographics and economics of the San Joaquin Valley region against California as a whol e, and provides a context for understanding demographic and economic changes that occurred within the San Joaquin Valley region between 1994 and 2004. Subsection 5.2 provides a context to understanding the inflation that occurred between 1994 and 2004. The subsequent subsections narrow the focus of the socioeconomic analysis to industries affected by Draft Rule 4570 and describes the economic characteristics of potentially impacted industries subject to Rule 4750. In this report, the San Joaquin Va lley region is defined as Fresno, Kern, Kings, Madera, Merced, San Joaquin, Stanislaus and Tulare counties. Data for Kern County in Tables 1 and 2 are for all of Kern County, although Kern County is only partially in the San Joaquin Valley Air Basin. Starting with Table 3, data for Kern County are for the part of Kern County that is within the San Joaquin Valley Air

Basin. 5.1 regional demographic and economic trends Regional Demographic Trends The San Joaquin Valley region experienced tremen dous population growth during the 1990s. Many came to this area because of affordable housing. As a result, population increased significantly. The eight-county region’s population increased by 22 pe rcent (or approximately 2.0 percent annually),

from 3.0 million in 1994 to 3.6 million in 2004. Wh ile the State of California’s population increased by 15 percent (or approximately 1 percent annually), all the counties in the region experienced faster rates of growth than California, and two counties grew at rates that were triple the State’s growth rate, as Table 1 shows. While, by many standards, Madera County continues to be a small county– at 136,923 residents according to the Department of Finance–it still experienced an annual growth rate of three percent between 1994 and 2004. Kings County also grew by three percent per year between

1999 and 2004. As demonstrated in the fo llowing section on regional economic trends, the demographic changes that occurred in the San Joaq uin Valley region during the 1990s significantly influenced the economy of this eight-county region.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 119 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 TABLE 2 Population Growth: San Joaquin Valley Region, 1994 - 2004

1994 1999 2004 Distribution,

2004 Annual %

Chng

94-99 Annual %

Chng

99-04 Annual %

Chng

94-04

California 31,661,024 33,765,185 36,271,091 1% 1% 1%

SJV Region 3,012,026 3,238,675 3,642,937 1% 2% 2%

Fresno 735,187 789,680 866,523 24% 1% 2% 2%

Kern 604,183 645,881 732,401 20% 1% 3% 2%

Kings 111,942 125,762 141,510 4% 2% 2% 2%

Madera 103,779 115,649 136,923 4% 2% 3% 3%

Merced 195,863 205,725 234,169 6% 1% 3% 2%

San Joaquin 513,135 557,086 636,466 17% 2% 3% 2%

Stanislaus 407,103 435,459 494,822 14% 1% 3% 2%

Tulare 340,834 363,433 400,123 11% 1% 2% 2%

Source: Applied Development Economics, based on California Department of Finance

Regional Economic Trends Economic development practitioners and planners have traditionally divided economies into two broad industrial categories—the economic base and local support industries. Economic base industries are the drivers of local and regional economies in that these industries draw income into a local economy by selling products outside of the lo cal economy, much like the export industries of a national economy. Accrued earnings then circulate throughout the local area in the form of wages and salaries; investments; purchase s of fixed assets, goods, and services; and generation of more jobs

and wealth. The economic base is typically comprised of indust ries within the manufacturing, minerals-resource extraction, and agricultural sectors. There are also the “local support industries” such as retail or service sectors, the progress of which is a functi on of the economic base and demographic changes,

and more so the latter than the former. As population increases in a given area, demand for services–such as realtors, teachers, and healthcare –increases, as does demand for basic retail items like groceries, gas for commuting, or clothing at the local apparel shops. Agriculture is the economic base of the San Joaqui n Valley region by virtue of the amount of goods this sector produces and exports throughout the nation and the globe. Fourteen percent of all workers in the region are employed by industries wi thin agriculture, as Table 2 shows. However, in 1999 the proportion of workers in agriculture was 17 percent. In fact, over the five-year period between 1999 and 2004, employment in agriculture declined by three percent per year, or by 15 percent over five years. Between 1999 and 2004, local support industries gained in prominence within the San Joaquin Valley region. Service-rendering industries empl oyed the most workers as a proportion of total employment in the region. As Table 2 shows, exclud ing wholesale, retail, and transportation, servicerendering industries comprise the largest employment sector in the region, at 661,900 or 53 percent of all jobs. With retail, transportation and wholesale, services accounting for almost 69 percent of all jobs. In 1999, service-rendering industries represented 50 percent of all jobs, and when including retail, wholesale, and transportation in the mix, 66 percent.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 120 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Increases in employment in service-rendering industries are consistent with regional population growth. In the region, local support industries of construction, education and health, financial activities, and government increased annually by six percent, three percent, two percent, and two percent respectively between 1999 and 2004.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 121 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 TABLE 3 Employment Profile Of The San Joaquin Valley Region 1999 – 2004

MAJOR SECTORS San Joaquin

Valley Region

Employment

1999 San Joaquin

Valley Region

Employment

2004 San Joaquin

Valley Region

Employment

Distribution,

2004 Annual Percent

Change

1999 to 2004 California

Employment

Distribution,

2003 Annual Percent

Change

(California)

1998 to 2003

Agriculture 199,400 172,200 14% -2.9% 2% -1.7%

Resources, Mining and Construction 62,400 85,100 7% 6.4% 6% 4.2%

Manufacturing 114,600 113,400 9% -0.2% 10% -3.5%

Wholesale 35,300 39,000 3% 2.0% 4% 0.8%

Retail 123,300 135,300 11% 1.9% 11% 1.4%

Transportation/Warehousing/Utilities 39,500 44,700 4% 2.5% 3% -1.0%

Information 15,300 16,100 1% 1.0% 3% -1.4%

Financial Activities 41,700 46,000 4% 2.0% 6% 2.6%

Professional and Business Services 92,800 98,300 8% 1.2% 14% -0.2%

Educational and Health Services 105,300 124,300 10% 3.4% 10% 2.7%

Leisure, Hospitality and Other Srvs 115,400 127,000 10% 1.9% 13% 1.9%

Government 228,300 250,200 20% 1.8% 16% 1.3%

Total Employment 1,173,300 1,251,600 100.0% 1.3% 100.0% 0.7%

Source: Applied Development Economics, based on data from California Employment Development Department LMID

The emergence of local support industries in the San Joaquin Valley region mirrors and leads statewide trends, as Table 2 shows. In the region, construction, health-education, and government increased annually by six percent, three percen t, and two percent, whereas, statewide, these industries grew by four percent, slightly under three percent, and one percent per year between 1999 and 2004. In short, while agriculture remains the leading edge of the economy, the San Joaquin Valley region’s economy has become more diverse, with the growth occurring within populationdriven local support industries rather than th e export-focused economic base industries of manufacturing and agriculture.

5.2 General Inflation Trends Figure 2 below tracks annual inflation between 1994 and 2004. Inflation is presented in this figure on a discrete annual basis (bars), as well as on cumu lative and compounded bases (lines). This report

converts both 1994 and 1999 revenue data into 2004 dollars using the inflation trends presented in Figure 2. For a detailed explanation on converting 1994 and 1999 revenue, see Attachment A.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 122 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 FIGURE 2

United States Bureau of Labor Statistics: Consumer Price Index (US Urban Wages), 1994-2004

3.7% 4.2% 4.5%

3.6%

2.5% 3.6% 5.6%

4.9%

2.8% 4.1% 4.9%

0% 1% 2% 3% 4% 5% 6%

1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 Cumulative
Index o f C hange

1994-2004

2 0 0 4 = 1 4 9 %

1 9 9 4 = 1 0 0 %

5.3 description of affected industries The analysis below discusses global, national, state, and regional trends with respect to industries subject to Draft Rule 4570. For purposes of cont ext, the discussion below starts with broad global and national trends, focusing particularly on wo rld export market for cattle, poultry, and hogs. Then, the discussion moves to state and regional trends.

Global Trends Tables 3, 4, 5 and 6 below track trends of the 20 leading world exporters of cattle, chickens, and hogs. Table 3 tracks milk and cheese exports of the United States and the top twenty leading exporters of these products. Thes e countries export $2.3 billion of milk and $14.1 billion of whole milk cheese to markets across the globe. As the world supply of milk and cheese increased between 1999 and 2004, the unit per metric ton price fell: milk by 5.5 percent per year and cheese by 4.0 percent per year. While the United States exports milk abroad, its share of the global market is relatively small at one percent. In fact, the Uni ted States dropped out of the UN FAO’s 2004 list of top twenty exporters of milk. US chees e exports is also small at 2.6 percent of the global market. In other words, US milk and cheese producers sell thei r products primarily to the domestic market. Table 4 shows that the aggregate and average values of cattle on the export market declined by three percent annually between 1999 and 2004, while the nu mber cattle in the export market also declinedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 123 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 by two percent annually between 1999 and 2004. US exports to the world declined precipitously in the year 2004, largely because of "mad cow" disease found in Canada; Canada stopped importing cattle in 2003 and into 2004, hurting American livesto ck producers. Canada is the largest market of US exports. World exports of chicken by the twenty leadin g countries increased modestly by one percent annually between 1999 and 2004, although Amer ican exports dropped significantly by 12 percent (Table 5). Supply of chicken on the world market increased by four percent per year, going from 552 million to 734 million chickens. The increase in supply may have influenced the decline in world prices on a per unit basis. At $1.25 per pound, worl d chicken prices are less than American prices of $1.71, which may also partly explai n the decline in American exports.SAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix C: 2006 Final Staff Report submitted with SIP June 18, 2009Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006Applied Development EconomicsC-124Final Staff Report with AppendicesFor Proposed Rule 4570TABLE 4Milk and Cheese Trends: United States and Top Twenty Leading Exporters 1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04US exports Milk Metric tons 44,368 10,276 data unavailable -25.4%Value $82,167,961 $28,731,924 data unavailable -19.0%Value per ton $1,852 $2,796 ----- 8.6%Top 20 Exporters Milk Metric tons 2,828,199 3,930,046 5,110,584 6.8% 5.4% 6.1%Value $2,276,796,892 $2,907,676,944 $2,338,231,000 5.0% -4.3% 0.3%Value per ton $805 $740 $458 -1.7% -9.2% -5.5%US exports Cheese Metric tons 24,761 43,121 62,371 11.7% 7.7% 9.7%Value $141,648,453 $461,068,729 $201,410,000 26.6% -15.3% 3.6%Value per ton $5,721 $10,692 $3,229 13.3% -21.3% -5.6%Top 20 Exporters Cheese Metric tons 2,254,202 2,649,151 3,537,665 3.3% 6.0% 4.6%Value $13,542,828,867 $17,573,353,850 $14,131,749,000 5.3% -4.3% 0.4%Value per ton $6,008 $6,634 $3,995 2.0% -9.6% -4.0%Source: Applied Development Economics, based on UN Foodand Agriculture OrganizationTABLE 5Cattle Export Trends: United States andTop Twenty Leading Exporters 1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04US ExportsAggregate Value $277,974,364 $216,460,012 Data unavailable -5%Number of heads 468,715 329,437 15,721 -7%Per head Price $593 $657 ------- 2%Top 20 ExportersAggregate Value $6,853,666,560 $4,758,106,126 $4,076,059,000 -7% -3% -5%Number of heads 7,942,994 8,105,452 7,199,065 0% -2% -1%Per head Price $863 $587 $566 -7% -1% -4%Source: Applied Development Economics, based on UN Foodand Agriculture OrganizationSAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix C: 2006 Final Staff Report submitted with SIP June 18, 2009Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006Applied Development EconomicsC-125Final Staff Report with AppendicesFor Proposed Rule 4570TABLE 6Chicken Industry Export Trends: United Statesand Top Twenty Leading Exporters 1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04US ExportsAggregate Value $167,963,235 $127,290,942 $66,514,000 -5% -12% -9%Number of heads 62,443,000 45,159,000 39,011,000 -6% -3% -5%Per head Price $2.69 $2.82 $1.71 1% -10% -4%Top 20 ExportersAggregate Value $1,001,053,610 $857,081,816 $919,656,000 -3% 1% -1%Number of heads 510,529,000 552,076,000 734,069,000 2% 6% 4%Per head Price $1.96 $1.55 $1.25 -5% -4% -4%Source: Applied Development Economics, based on UN Foodand Agriculture OrganizationTABLE 7Swine Industry Export Trends: United States and Tope Twenty Leading Global Exporters 1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04United StatesAggregate Value $59,629,458 $35,126,192 $32,140,630 -10% -1.8% -6%Number of heads 386,380 348,109 337,983 -2% -0.6% -1%Per head Price $154 $101 $95 -8% -1.2% -5%Top 20 ExportersAggregate Value $69,869,506 $38,882,171 $39,293,974 -11% 0.2% -6%Number of heads 463,000 399,000 352,000 -3% -3% -3%Per head Price $151 $97 $112 -8% 3% -3%Source: Applied Development Economics, based on State of California AgriculturalCommissioners Annual Report. Data incudes federal subsidies (EWG. Farm Subsidies Database)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 126 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 National Trends Tables 7 through 11 track national trends with respect to production and value for cattle, dairy cows, broiler chickens, and hogs. Table 7 shows that, on average, dairy cows produced 19,107 pounds of milk in 2004, an improvement over five years before, when cows produced 18,109 pounds per milk. Between 1999 and 2004, the number of dairy cows declined slig htly by 0.2 percent per year, while milk production increased from 140 billion to 147 billion pounds of

milk. Tables 8 and 9 track national trends with respect to cattle. Table 8 shows that during the ten-year period stretching from 1994 to 2004,

the number of cattle declined relati vely evenly at a smooth rate of 0.6 percent per year, and this rate of decline more or less held for most kinds of cattle. The unit price of different kinds of cattle declined at a faster rate in inflation-adjusted terms (Table 9). Table 10 shows that on a per head or per pound basis, chicken prices in the United States have increased significantly between 1999 and 2004 in inflation-adjusted terms. The value of the chicken industry was $24 billion in 2004, up $5 b illion from the figure for 1999. Chicken in 2004 sold for $0.71 per pound, versus $0.46 five years before, resulting in a nine-percent annual growth rate.SAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix C: 2006 Final Staff Report submitted with SIP June 18, 2009Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006Applied Development EconomicsC-127Final Staff Report with AppendicesFor Proposed Re-Adoption of Rule 4570TABLE 8Dairy Industry Trends: United States, 1994-20041994 1999 2004 94-99 99-04 94-04Nation Nos. of Milk Cows 7,861,833 7,734,333 7,712,962 -0.3% -0.1% -0.2%Pounds of Milk 129,712,000,000 $140,062,000,000 147,373,402,231 2% 1% 1%Average Production 16,499 18,109 19,107 2% 1% 1%Source: Applied Development Economics, based on USDA ERS Economic OutlookTABLE 9Cattle Industry Trends: United States, 1994-20041994 1999 2004 94-99 99-04 94-04Milk cows 9,507,000 9,128,000 8,990,000 -0.8% -0.3% -0.6%Dairy heifers 4,125,000 4,069,000 4,020,000 -0.3% -0.2% -0.3%Beef cows 34,603,000 33,750,000 32,861,000 -0.5% -0.5% -0.5%Beef Heifers 6,364,000 5,535,000 5,518,000 -2.8% -0.1% -1.4%Other heifers 9,104,000 10,170,000 9,806,000 2.2% -0.7% 0.7%Steers >500 lb. 17,086,000 16,891,000 16,277,000 -0.2% -0.7% -0.5%Bulls 2,312,000 2,281,000 2,206,000 -0.3% -0.7% -0.5%Calves 17,873,000 17,290,000 15,210,000 -0.7% -2.5% -1.6%Total Cattle 100,974,000 99,114,000 94,888,000 -0.4% -0.9% -0.6%Source: Applied Development Economics, based on USDA ERS Economic OutlookSAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix C: 2006 Final Staff Report submitted with SIP June 18, 2009Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006Applied Development EconomicsC-128Final Staff Report with AppendicesFor Proposed Re-Adoption of Rule 4570TABLE 10Unit Price of Cattle, 1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04Cattle pricesSteers, Choice, 11-13 cwtTexas Panhandle $103.68 $81.93 $83.51 -4.6% 0.4% -2.1%Nebraska Direct $102.55 $81.53 $84.69 -4.5% 0.8% -1.9%Cows - Sioux FallsUtility breaking 1200-1600 lbs. $71.92 $56.38 $53.88 -4.8% -0.9% -2.8%Utility boning 800-1200 lbs. $70.78 $45.00 $46.62 -8.7% 0.7% -4.1%Feeder Cattle - Oklahoma CitySteers: Med. #1500-550 lb $135.60 $110.92 $103.10 -3.9% -1.5% -2.7%600-650 lb $124.00 $102.77 $95.21 -3.7% -1.5% -2.6%750-800 lb $115.78 $94.99 $89.85 -3.9% -1.1% -2.5%Heifers: Med. #1450-500 lb $124.63 $101.40 $95.23 -4.0% -1.2% -2.7%700-750 lb $111.06 $89.41 $85.88 -4.2% -0.8% -2.5%Source: Applied Development Economics, based on USDA ERS Outlook, “Red Meat Yearbook”TABLE 11Trends in Broilers: United States 1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04Number of heads 7,017,540,000 8,146,010,000 7,065,621,427 3.0% -2.8% 0.1%Pounds 48,456,290,168 50,773,370,162 34,083,000,000 1% -8% -3%Gross Value $16,939,960,631 $18,813,273,477 $24,198,930,000 2% 5% 4%Value per head $2.41 $2.31 $3.42 -1% 8% 4%Value per pound $0.52 $0.46 $0.71 -2% 9% 3%SAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix C: 2006 Final Staff Report submitted with SIP June 18, 2009Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006Applied Development EconomicsC-129Final Staff Report with AppendicesFor Proposed Re-Adoption of Rule 4570TABLE 12Swine Trends: United States, 1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04Number of heads 59,738,000 59,335,000 60,975,000 -0.1% 0.5% 0.2%Per head Price: Sow $47.48 $23.95 $28.24 -13% 3% -5%Per head Price: Lean Hogs $62.57 $42.28 $39.45 -8% -1% -5%Source: Applied Development Economics, based on State of California AgriculturalCommissioners Annual Report. Data incudes federal subsidies (EWG. Farm Subsidies Database)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-130 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 State and Regional Trends The following discussion examines state and regional trends with respect to cattle, dairy, poultry an d hogs. The tables identify broad trends in these industries in the eight-county San Joaquin Valley region. Milk production in the region is a $4.3 billion and growing industry, increasing by 3.6 percent per year between 1999 and 2004 and, over a ten-year stretch, by 4.4 percent per year between 1994 and 2004 (see Table 12). The $4.3 billion amount represents the value of milk and other dairy products, not the value of the dairy

cows. Table 12 shows that beef cattle generated approximately $115.4 million in value in 2004, or less than three percent of the value of dairy industry in the region. Of the 4.2 million heads of cattle in the region, approximately four percent ar e beef cattle only. Because beef cattle are a small portion of the overa ll number of cattle in the region, greater aggregate value is found in cattle other than beef cattle, such as transactions involved in the buying and selling of dairy cows. As Table 13 and 14 show, all other cattle grew by 9.5 percent between 1999 and 2004, while the number of beef cattle declined by 1.8 percent per year. While the number and aggregate value of beef cattle in the region has declined and remains a small proportion of total cattle stock and aggregate value, at $709 per head, the average value of beef cattle is higher than the $598 average value of all other

cattle. Tables 15 and 16 track trends in swine and poultry industries. The swine industry in the region is considerably below peak production levels of 1994, when $59.6 milli on in value was generated off of 386,400 heads of hogs. Ten years later in 2004, regional swine facilities generated $27 million less value, or $32.1 million off of 338,000 heads of hogs. Similar to the dairy industry, producers of chicken broilers and eggs have enjoyed considerable growth in the region between the five years period spanning 1999 and 2004. The aggregate value of poultry has increased by 5.5 percent per year, while the per unit price increased by a respectable 2.9 percent per year. Overall, chicken is a $468 million industry in the eight- county region as of 2004 (see Table 16).SAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix C: 2006 Final Staff Report submitted with SIP June 18, 2009Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006Applied Development EconomicsC-131Final Staff Report with AppendicesFor Proposed Re-Adoption of Rule 4570TABLE 13Dairy Industry Trends: San Joaquin Valley Region and State of California, 1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04RegionAggregate Value $2,800,920,159 $3,614,087,130 $4,321,127,613 5.2% 3.6% 4.4%Production (Cwt) 164,346,457 216,804,199 292,249,472 5.7% 6.2% 5.9%Per Unit Price $17.01 $16.63 $14.72 -0.5% -2.4% -1.4%State TotalsAggregate Value $3,752,975,256 $4,600,277,044 $5,304,938,310 4.1% 2.9% 3.5%Production (Cwt) 218,037,547 274,337,967 358,445,714 4.7% 5.5% 5.1%Per Unit Price $17.18 $16.72 $14.73 -0.5% -2.5% -1.5%Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data includes federal subsidies (EWG. Farm Subsidies Database)TABLE 14Cattle and Calves Industry Trends: Beef Cattle Only: San Joaquin Valley Region and State of California1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04RegionAggregate Value $148,326,932 $126,636,712 $115,441,165 -3.1% -1.8% -2.5%Number of heads 170,470 195,578 162,800 2.8% -3.6% -0.5%Per head Price $870 $648 $709 -5.7% 1.8% -2.0%State TotalsAggregate Value $791,190,182 $542,886,300 $544,104,000 -7.3% 0.0% -3.7%Number of heads 841,146 810,000 720,000 -0.8% -2.3% -1.5%Per head Price $941 $670 $756 -6.6% 2.4% -2.2%Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data includes federal subsidies (EWG. Farm Subsidies Database)SAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix C: 2006 Final Staff Report submitted with SIP June 18, 2009Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006Applied Development EconomicsC-132Final Staff Report with AppendicesFor Proposed Re-Adoption of Rule 4570TABLE 16Swine Industry Trends: All Other Cattle: San Joaquin Valley Region and State of California1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04RegionAggregate Value $59,629,458 $35,126,192 $32,140,630 -10.0% -1.8% -6.0%Number of heads 386,380 348,109 337,983 -2.1% -0.6% -1.3%Per head Price $154 $101 $95 -8.1% -1.2% -4.7%State TotalsAggregate Value $69,869,506 $38,882,171 $39,293,974 -11.1% 0.2% -5.6%Number of heads 463,000 399,000 352,000 -2.9% -2.5% -2.7%Per head Price $151 $97 $112 -8.4% 2.8% -3.0%Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data includes federal subsidies (EWG. Farm Subsidies Database)TABLE 15Cattle and Calves Industry Trends: All Cattle Other than Beef and Dairy: San Joaquin Valley Region and State of California1994-2004 ($2004)1994 1999 2004 94-99 99-04 94-04RegionAggregate Value $829,410,576 $854,776,429 $1,346,087,835 0.6% 9.5% 5.0%Number of heads 1,534,709 1,740,622 2,251,367 2.6% 5.3% 3.9%Per head Price $540 $491 $598 -1.9% 4.0% 1.0%State TotalsAggregate Value $1,311,021,059 $1,309,106,879 $1,917,232,892 0.0% 7.9% 3.9%Number of heads 3,958,854 4,290,000 4,680,000 1.6% 1.8% 1.7%Per head Price $331 $305 $410 -1.6% 6.1% 2.2%Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data includes federal subsidies (EWG. Farm Subsidies Database)SAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix C: 2006 Final Staff Report submitted with SIP June 18, 2009Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006Applied Development EconomicsC-133Final Staff Report with AppendicesFor Proposed Re-Adoption of Rule 4570TABLE 17Poultry and Eggs Industry Trends: San JoaquinValley Region and State of California, 1994-20041994 1999 2004 94-99 99-04 94-04RegionAggregate Value: Poultry$352,813,215 $359,030,294 $468,232,000 0.3% 5.5% 2.9%Pounds of poultry 641,431,000 700,211,319 791,409,389 1.8% 2.5% 2.1%Poultry value per pound $0.55 $0.51 $0.59 -1.4% 2.9% 0.7%Aggregate Value: Eggs $162,733,051 $84,810,472 $132,460,000 -12.2% 9.3% -2.0%Dozens 192,527,246 132,268,002 187,341,125 -7.2% 7.2% -0.3%Eggs value per dozen $0.85 $0.64 $0.71 -5.4% 2.0% -1.8%StateAggregate Value: Poultry $391,348,691 $389,761,080 $689,303,956 -0.1% 12.1% 5.8%Pounds of poultry* 1,131,000,000 Data unavailable Data unavailablePoultry value per pound $0.35 ------- -------Aggregate Value: Eggs $374,008,792 $265,620,390 $268,459,200 -6.6% 0.2% -3.3%Dozens 525,177,391 464,225,339 421,083,000 -2.4% -1.9% -2.2%Eggs value per dozen $0.71 $0.57 $0.64 -4.3% 2.2% -1.1%Source: Applied Development Economics, based on State of California AgriculturalCommissioners Annual Report and Annual Crop Report (various counties) (*Cal stopped publishing pounds for reasonsof confidentiality)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-134 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 5.4 Net Profit Ratios

Table 17 tracks net profit ratios for industries subject to Draft Rule 4570 fr om 1992 to 2002. Data comes from Dun and Bradstreet. Dun and Bradstreet tracks a wide variety of business and financial indica tors, including after tax net profit, and these indicators are based on performance of a representative sample of establishments from across the country in a particular industry at the fo ur-digit Standard Industrial Classificati on (SIC) level. Dun and Bradstreet track information on annual bases, allowing us to calculate a weighted average after ta x net profit ratio that smoothens out the

affects of economics booms and recessions. We also examined net profit ratios calculated by the United States Department of Agriculture (USDA). According to the USDA, dairy and hogs farmers across the country performed relatively well over the 10-year period stretching from 1994 to 2004, recording a ten-year net profit average of 6.2 percent and 10.8 percent respectively. In the table below, “upper quartile” refers to th e top performing businesses within an industry in terms of net prof it ratios, specifically those in the top 25 percent. “Lower quartile” refers to businesses with the lowest net profit ratios.

TABLE 18

Net Profit Ratios : Dun and Bradstreet 1992-2002

Description SIC Code Level 10-year avg.

Upper Quartile 14.9

General farms, primarily crops 0191 Median 5.9

Lower Quartile 1.2

Upper Quartile 6.0

Beef cattle feedlots 0211 Median 2.7

Lower Quartile 1.0

Upper Quartile 18.4

Beef cattle, except feedlots 0212 Median 5.6

Lower Quartile -2.3

Upper Quartile 9.3

Hogs 0213 Median 2.9

Lower Quartile -2.5

Upper Quartile 11.1

Dairy farms 0241 Median 3.7

Lower Quartile 0.4

Source: Dun and Bradstreet

5.5 Economic Characteristics of Affected Sources

Table 18 through 20 apply the ten-year average after tax net prof it ratio discussed above to in dustries affected by Rule 4750, to generate an economic profile of affected industries in the region in terms of their respective numbers, employment, revenue, an d net profits.

Table 18 shows that there are approximat ely 1,500 dairy farmers operating in the eight-county region, and these farmers employ an estimated 16,800 workers. 2 These dairy farms recorded $4.3 billion in value, off of which $266 million in net profits was generated. It is important to note that the ec onomic activity tracked in Table 18 involved milk production,

2 The California Employment Development Department (EDD) show that in all of California there are approximately 1,600 dairy farms and, in the eight-county region, 1,141 dairy farms. However, the USDA field office in California, which annually publishes a report called, “California Agricultural Statistics,” indicates that there are 1,500 dairy farms operating in the region, and 2,104 in the state as a whole. The discrepancy is largely attributable to the fact that the California EDD organizes its data by the primary activity establishment is engaged in. So, if dairy production is a secondary ac tivity of an establishment that is prim arily engaged, say, wheat farming, the California EDD will place this company in wheat farming industry cluster. On the other hand, both the USDA and the US Agricultural Census will place this establishment in both da iry and wheat industry groups.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-135 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 not purchase or sale of dairy cows. Tabl e 19 tracks transactions involving the sale of cattle in general and beef cattle in particular.

The cattle industry in the region is not as large as dairy, employing less number of workers and generating less revenues and net profit (see Table 19). The beef cattle and other cattle industry em ploy an estimated 10,474 workers in the region, out of 18,144 who are employed thro ughout the state. It should be note d that official statistics from the California Employment Development Depa rtment (EDD) show that in all of California there are approximately 861 cattle farms and, in the eight-county region, 235. However, the USDA Agricu ltural Census 2002 in dicated that there were 17,380 and 5,860 cattle farms in the state and region re spectively in the year 2002. Projecting to 2004 based on California EDD growth patterns between 2002 and 2004, we estimate that there ar e 16,212 cattle farms in the state and 5,290 in the region. The discrepancy betw een the EDD and Agricultural Census data sets is important as it bears on the number of workers employed in the cattle industry. The discre pancy is largely attributable to the fact that the California EDD organizes its data by the primary activity an establis hment is engaged in. So, if cattle farming is a secondary activity of a farm establishment that is primarily engaged in, say, wheat farm ing, the California EDD will place this company in wheat farming industry group. On the other hand , US Agricultural Census will place this establishment in both dairy and wheat industry groups. In estimating the number of workers based on both the California EDD and US Agricultural Census data sets, we do not simply apply the ratio of cattle workers to cattle farms in the EDD dataset to the number of farms in the Agricultural Census data set, as this would overestimate the number of workers because approximately twenty of the farms engaged in cattle activity actually hire workers. Thus, we estimate that there are approximately 10,474 workers employed in beef cattle and other cattle operations in the regi on, not 2,623 as indicated by the California EDD. In addition to empl oyment, Table 20 includes revenue and net profit estimates for operators in the region and state.

Table 20 shows trends in the swine industry in the region an d state. There are approximat ely 313 farms operating in the region and 1,485 in the state as a whole, suggesting that swine farm operations occurs largely outside of the eight-county region.SAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix C: 2006 Final Staff Report submitted with SIP June 18, 2009Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006Applied Development EconomicsC-136Final Staff Report with AppendicesFor Proposed Re-Adoption of Rule 4570TABLE 19Dairy Industry Profile: San Joaquin Valley Region and the State, 2004Dairies Emp (est) Aggregate Wages Dairy Cows (est) Production (CwT) Value Value\CwT Est. Net ProfitCalifornia 2,104 21,228 $532,980,310 1,735,800 358,445,714 $5,304,938,310 $14.73 $326,480,174Region 1,500 16,805 $417,710,983 1,406,106 292,249,472 $4,321,127,613 $14.72 $265,933,817Source: USDA, NASS Field Office, "California Agricultural Statistics 2004", California Agricultural Commissioners, and USDA ERSTABLE 20Cattle Industry Profile: San Joaquin Valley Region and the State, 2004Cattle Operations Employment Aggregate Wages Nos.of heads Value Value per head Est. Net ProfitCalifornia 16,212 18,144 $462,496,692 5,400,000 $2,461,336,892 $456 $121,022,378Region 5,290 10,474 $271,741,535 2,414,167 $1,461,529,000 $605 $61,384,218Source: California Agricultural Commissioners (number of cattle [head] and value), US Ag Census 2002 (cattle farms), Ca EDD (establishments, employment and wages) and DnB(net profit)TABLE 21Swine Industry Profile: San Joaquin Valley Region and the State, 2004Swine Farms Employment Aggregate Wages Hogs sold Aggregate Value Value per head Est. Net ProfitCalifornia 1,485 4,137 $106,844,324 352,000 $39,293,974 $112 $1,139,525Region 313 872 $22,526,459 337,983 $32,140,630 $95 $932,078Source: California Agricultural Commissioners(number of hogs [head] and value), US AgCensus 2002 (hog farms), Ca EDD (establishments, employment and wages), DnB (netprofit) and USDA ERS (net profits)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-137 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

## 6. SOCIOECONOMIC IMPACTS

This section of the report compares the economic characterist ics of affected industries against the compliance costs. The first part of this section discusses annual compliance co sts. Section 6.2 discusses general business responses to compliance costs. Section 6.3 analyzes th e socioeconomic impacts of Draft Rule 4750. 6.1 compliance cost estimates

Table 21 below identifies annual costs a ssociated with Draft Rule 4570. The ta ble summarizes costs estimates based on data provided by the San Joaquin Valley Unified Air Pollu tion Control District. For detailed discussion on the cost estimates, we direct your attention to a report issued by th e District called “Appendix C: Cost Effectiveness Analysis for

Rule 4570.”

TABLE 22 Socioeconomic Impact Analysis : Annual Cost of Compliance

Total Annual

Compliance Costs

Swine CAF $540

Dairy CAF $18,324,074

Beef CAF $590,112

Other Cattle CAF $7,147,266

Source: Applied Development Economics, based on San Joaquin Valley Unified Air
Pollution Control District and Industry

By far, the largest cost involved with Rule 4570 will be borne by dairy operators. This section of the report discusses the methodology employed in calculating co sts borne by affected dairy farms. The same methodology was used for beef
feedlots, other cattle facilit ies, and swine facilities. First, we need to consider how many dairies farms and m ilk and other cows will be subject to the rule. There are approximately 1,500 dairy farms in the region and, of these, 430 are subject to the rule. An d, of the 430 dairy farms, 233 are out of compliance and will have to implemen t measures in Rule 4570. Since 54 percent (233 ÷ 430=54%) of the large dairy CAFs are out of compliance, District staff assumed that 54 percent of the animals at the large dairy CAFs are at facilities that will need to implement additional mitigati on measures. This means that 494,177 milk cows; 79,068 dry cows; and 444,759 other support cows, for a total of 1,018,004 animals cows of varying sizes and ages are housed at facilities that will be affected by the rule requirements. The District estimates the overall cost of the Dairy CAF at $18.00 per head of cow. In calculating this figure, the District includ ed some cost activities that are attributable only to milk cows and not to support cows. This was taken into account when we determine th at the average cost per head of cows on the facility was $18.00. The $18.00 per head was multiplied by the total dairy cows at facilities that are not in compliance (1,018,004 cows). Thus , we arrive at the annual cost of comp liance figure of $18,324,000 for the Dairy CAF portion of Rule 4570. 6.2 business responses to compliance costs
Industries impacted by the draft rule may respond in a variety of ways when faced with new regulatory costs. These responses may range from simply absorbing the costs and accepting a lower rate of return, to shutting down the affected business operation altogether an d, where practical, shift from lower-value to higher-value product and or crop. Affected sources may also seek to renew efforts to increase productivi ty and reduce costs elsewhere in their operation in order to recoup the regulatory costs and maintain pr ofit levels. It is importa nt to note that agriculture in general, and livestock products in particular, are “price takers ”, meaning that they have little ability to set price of their goods, and little abili ty to pass on costs to the consumer. As pr ices of basic goods like beef increase, consumers may switch to other products, such as poultry. Alternatively, consumers might continue to buy beef, but they may switch to products from other regions or states that could be less expensive.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-138 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 6.3 IMPACTS ON AFFECTED INDUSTRIES This section of the report analyzes estimated after tax ne t profits of affected industri es against anticipated costs associated with implementation of the draft rule. The net pr ofit of affected sources was calculated by multiplying the total net profit of the industry in the San Joaquin Valley (from Table 18, 19, and 20) by the percent of animals at facilities subject to the rule. The results of thes e calculations are shown in Table 22.

TABLE 23 Socioeconomic Impact Analysis Rule 4570: Net Profits

Percent of

Animals at

Facilities

Subject to Rule

4570 Total Profits

from the

Industry Estimated Net Profit of Affected

Sources

Dairy 72% $265,933,817 $191,472,348

Cattle 95% $60,653,454 $57,620,781

Beef 95% $4,790,808 $4,551,268

Other Cattle 95% $55,862,645 $53,069,513

Swine 57% $932,078 $531,284

The estimated annual compliance costs used in this analysis were provided to ADE by Dist rict staff and stakeholders. Table 23 below compares the total annual compliance costs disc ussed above against estimated net profits of stakeholders that will be subject to the rule shown in Table 22.

TABLE 24 Socioeconomic Impact Analysis Rule 4570: Impact on Net Profits

All AFOs Affected AFOs Est. Net Profit of Affected

Sources Annual Cost Annual Cost

As % Net

profits

Dairies 1,500 233 $191,472,348 $18,324,074 9.6%

Cattle 5,290 11 $57,620,781 $8,327,490 14.5%

Beef 6 $4,551,268 $590,112 13.0%

Other Cattle 5 $53,069,513 $7,147,266 13.5%

Swine\Hogs 313 3 $531,284 $540 0.1%

Poultry NA NA NA NA NA

Sources: Applied Developm ent Economics, based on Ca lifornia Agricultural Commissioners, US Ag Census 2002, Ca EDD, DnB and ESDA ERS

Both beef cattle operators and other catt le operators are impacted by the rule, as their annual costs of $590,112 and $7.1 million amounts to 13 percent and 13.5 percent of net profits, or three to four percentage points above the significance

threshold. Table 23 shows that the rule can result in a loss of 9.6 percent of net profits of affected dairy operators, $18 million in annual compliance cost s out of $191 million in estima ted annual profits. This impact is below the ten percent threshold of significance employed for the purposes of eval uating the impact of air qualit y rules. Swine and poultry producers are also not impacted by the rule in any significant manner. Table 24 includes direct employment impacts associated with the amount of impacts on profits above the threshold of significance. Because of the way in which one business in one industry interacts through buye r and supplier relations with businesses
in the same or other industries, we also need to understand the indirect and what are called induced impacts associated with the draft rule. Using the IMPLAN Impro Professional i nput-output model, the consultant estimated the multiplierSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-139 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 impacts associated with the cost of compliance above the thre shold of significance, looking particularly at two measures – employment and industry output. Th ese measures are defined as follows:

 Employment indicates the number of jobs lost given the level of compliance cost. This employment total includes self-employment.

 Industry output represents the sum of all economic activity lost by affected industries and ancillary activities. This activity includes all commodity inputs, labor income, property income, and other value added components.

The multiplier impacts for these measures come from the Type II multipliers. These multipliers include the direct, indirect, and induced impacts. These mult iplier descriptions ar e summarized below.

 Direct impacts represent the jobs losses and other economic impacts that are directly related to costs associated by affected industries as a result of implementation of the draft rule.

 Indirect impacts represent the jobs and other economic effects that will potentially be lost elsewhere in the eight- county region as a result of the direct impacts on affected industries resulting from the draft rule. These indirect impacts result from supplier purchases.

 Induced impacts represent the economic losses a ssociated with reductions in household purchases tied to direct an d indirect employment losses in the region. These induced impacts most ty pically occur in retail and other localserving industry categories such as pe rsonal services, education, and health

care.

Table 24 shows the direct, indirect and in duced employment impacts associated with annual cost of compliance resulting

from Draft Rule 4570. In addition to the direct loss of 17 workers in the other cattle indust ry, there will be an indirect

loss of 17 additional workers in businesses with whom affect ed cattle producers engage in buyer-supplier relations. The
direct loss of 17 and the indirect loss of another 17 workers, in turn, will induce the loss of another 6.4 workers, mainly those who are employed in retail and services. Thus, the total nu mber of jobs lost as a result of the costs associated with
Draft Rule 4570 amounts to 40.4 workers, or less than 0.1 percent of the numb er of people employed by the cattle industry in the region.

TABLE 25 Socioeconomic Impact Analysis: Rule 4570

Scenario Direct Impacts Indirect Impacts Induced Impacts Total Impacts

Dairy Industry Output Impacts -- below sig. -- -- below sig. -- -- below sig. -- -- below sig. --

Employment Impacts -- below sig. -- -- below sig. -- -- below sig. -- -- below sig. --

Cattle Industry Output Impacts $1,975,300 $1,806,328 $415,641 $4,197,269

Employment Impacts 17 17 6.4 40.4

Beef Industry Output Impacts $134,985 $123,438 $28,403 $286,827

Employment Impacts 1 1 0.4 2.4

Other Cattle Industry Output Impacts $1,840,315 $1,682,890 $387,238 $3,910,442

Employment Impacts 16 16 5 38

Swine Industry Output Impacts -- below sig. -- -- below sig. -- -- below sig. -- -- below sig. --

Employment Impacts -- below sig. -- -- below sig. -- -- below sig. -- -- below sig. --

Poultry Industry Output Impacts NA NA NA NASAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-140 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Employment Impacts NA NA NA NA

Source: Applied Development Economics, based on San Joaquin Valley Unified Air Pollution Control District and Industry

6.4 IMPACT ON SMALL BUSINESSES In addition to analyzing the employment impacts of Draft Rule 4570, state legislation re quires that the socioeconomic analysis assess whether small businesses are disproportionately affect ed by air quality rules. This section begins by briefly summarizing how the state governme nt defines small businesses for the purposes of qua lifying certain businesses for various programs. This section concludes with a discussi on as to whether the affected industries include small

businesses and assesses whet her those small businesses are disproportionately impacted by the new rules.

Definition Of A Small Business For purposes of qualifying small businesses for bid preferences on state contracts and other benefits, the State of California defines small businesses in the following manner 3 . To be eligible for small bu siness certification, a business:

 Must be independently owned and operated;

 Cannot be dominant in its field of operation;

 Must have its principal office located in California

 Must have its owners (or officers in the case of a corporation) domiciled
in California; and

 Together with its af filiates, be either:

• A business with 100 or fewer empl oyees, and an average gross receipts of $10 million or less ov er the previous tax years, or

• A manufacturer with 100 or fewer employees.

Based on conversation with Distri ct staff, who know the dairy and cattle companies impacted by the rule, we conclude that Rule 4570 does not disproportionate ly impact small business sources.

3 State of California. Department of General Servi ces. “California Small Business Certification” (http: www.pd.dgs.ca.gov/smbus/sbcert.htm)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-141 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

## ATTACHMENT A

Figure A below shows the rate at which the nominal price of a g ood should change from one yea r to the next, if it is to holds its value in inflation-adjusted term s. Most importantly, this chart allows us to compare revenue data that was issued in 2004 against data that was issued in previous years, part icularly 1994 and 1999.

FIGURE A

United States Bureau of Labor Statistics:
Consumer Price Index (US Urban Wages), 1994-2004

To maintain its inflation-adjusted va lue between 1994 and 1995, the price-tag of the $1.00 good in 1994 should read $1.042 one year later, due to 1994 to 1995 inflation of 4.2%. Over the course of a longer period, such as 1994 to 2004, the price-tag value of something that was $1.00 in 1994 should read $1.49, when converting 1994 data in 1994 dollars

into 2004 dollars. In short, if 1994 data indicating the valu e of something is $1.00 is compared agai nst 2004 data that indi cates the value of the same good is, say, $1.55, the correct comparison is no t between $1.00 (1994) and $1. 55 (2004). Rather, the correct comparison is between $1.49 (1994 in 2004 dollars) and $1.55 (2004), for a difference of $.06 as opposed to $.55. Analyses that do not account for inflati on run the risk of conveying less than accurate descri ptions of economic trends, oftentimes resulting in an overstatem ent of the magnitude of change that occurred between two points in time. While accounting for inflation for analytical purposes is fa irly straightforward, there are a number of other worthy considerations. It should be noted that businesses can not simp ly raise prices (change price ta gs as it were) to keep up with inflation. Upward shifts in prices from one year to the next could result in disproportionate re duction in sales. Many mass produced consumer goods compete primarily on price. Central Valley wine, for example, competes largely on price -- while Wine Country wines compete on quality and pr ice, meaning that consumers are more willing to spend more for quality wines from Napa, Marin, and Sonoma Counties. The same is not true for low-cost wine. As prices of 3.7% 4.2% 4.5%

3.6%

2.5% 3.6% 5.6%

4.9%

2.8% 4.1% 4.9%

0% 1% 2% 3% 4% 5% 6%

1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 Cumulative
Index o f C hange

1994-2004

2 0 0 4 = 1 4 9 %

1 9 9 4 = 1 0 0 %SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-142 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 these goods increase, consumers look to other low-cost substitutes, perhaps imports from Australia, in the case of lowcost wines. In the case of meats, unit increases in red me at may trigger shifts in consumption away from meat toward poultry, which typically costs less. 4

4 While many businesses cannot adjust their prices to acc ount for inflation for reasons related to market share and profitability, this is not entirely the case for all businesses an d industries. While businesses prefer higher prices that do not trigger losses in sales, many businesses are happy to sell goods at their previous year's price if productivity gains allow these companies to still generate a profit. Compan ies that sell at prices similar to the previous year can mitigate inflation risks and generate profit through impr oved supply chain management, or other innovations, such as adoption of better technologies or marketing strategies. Labor costs and other material input costs can also be held low to gain efficiencies in productionSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix D: Socioec onomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-143 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix E: Rule Consistency Analysis for Rule 4570 June 15, 2006

C-144 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

# APPENDIX E

RULE CONSISTENCY ANALYSIS PROPOSED RULE 4570 (CONFI NED ANIMAL FACILITIES)

June 15, 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix E: Rule Consistency Analysis for Rule 4570 June 15, 2006

C-145 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 RULE CONSISTENCY ANALYSIS FOR PROPOSED RULE 4570

I. Requirements for Rule Consistency Analysis

Pursuant to Section 40727.2 of the California Health and Safe ty Code, prior to adopting, amending of a rule or regulati on, the District is required to perform a written analysis that identifies and compares the air polluti on control elements of Rule 4570 with the corresponding elements of existing or proposed District and EPA regulations and guidelines that apply to confined animal facili ties. The elements that were analyzed are mitigation measures, monitoring and test ing, and recordkeeping and reporting requirements. Staff found that facilities could comply with Rule 4570 and all existing District Rules. Furthermore, staff found t hat none of the requir ements of Rule 4570

would conflict with State or Federal rules, regulations, or policies. The analysis is

discussed below.

II. Results of Analysis

A. District Rules

Rule 4570 would apply to confined animal fa cilities. Emission sources subject to proposed Rule 4570 are subjec t to the following rules:

• 3190 (Conservation Management Practice Fee )- This rule applies fees to recover costs for the District's Conservation Managem ent Practice. No sections of this rule and Proposed Rule 4570 contradict.

• 4550 (Conservation Management Practices)

• Poultry- No measures in Rule 4550 would affect a facility's options in proposed Rule 4570.

• Swine-Swine are exem pt from Rule 4550.

• Dairy and cattle operations- The decr eased moisture that reduces VOC

emissions can increase PM emissions. Since Rule 4550 is intended to reduce PM emissions while proposed Ru le 4570 is intended to reduce VOC emissions the options in Rule 4550 to increase moisture in pens and corrals to reduce PM emissions are incompatible with the options in Proposed Rule 4570 to reduce moisture in pens and corrals to reduce VOC emissions. However, both rules have sufficient options such that a facility could comply with both rule requirement s while choosing options that reduce moisture; choosing options that increase moistu re; or choosing options that do not

affect moisture.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix E: Rule Consistency Analysis for Rule 4570 June 15, 2006

C-146 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 B. Federal EPA Rules, Regulations, and Policies

1. Title 40 CFR Parts 9, 122, 123, and 412

Facilities shall obtain a National Pollutant Discharge Eliminati on System permit. Nothing in Rule 4570 woul d preclude this.

2. EPA “Control Techniques Gu ideline (CTG) Document

There is no EPA CTG for confined animal facilities.

3. EPA Policy on Recordkeeping

The recordkeeping requirement in Section 6.1 of Rule 4570 is consistent with EPA’s policy to keep and maintain record s for at least five years.

C. California Rules, Re gulations, and Policies

1. CCR Title 27 §13260 & 13263

These sections require any person dischargi ng or proposing to discharge wastes that could affect the quality of su rface or groundwater to notify the Regional Water Quality Board. The person shall impl ement state and federal wate r quality control policies as well as the Basin Plan for the applicable ar ea. Rule 4550 provides sufficient options such that no requirement s of the Regional Water Q uality Board would be in

contradiction with Rule 4550. Staff contacted David Sholes at the Central Valley Regional Water Quality Board (RWQB) and was told that the rule did not conflict with existing RWQB regulations and some of th e measures were RWQB requirements in

some cases.

2. CFR Title 27 §22560, 22561, 22562, 22563, 22564, and 22565

These sections specify general standard for confined animal facilities including preventing animals from ent ering surface water; requi rements for handling of wastewater; standards for land application of manure and wastewater; minimization of water in manured areas from infiltrating the underlying soils, and monitoring. No requirements of Rule 4570 would be incons istent with the goals and requirements of

these sections.

3. CCR Title 3, Division 2, Chapter 1, Article 21, §622

This section requires that no cross connections may be installed between safe and unsafe or questionable water supplies. No requirements in Rule 4570 would require

this.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix E: Rule Consistency Analysis for Rule 4570 June 15, 2006

C-147 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 4. CCR Title 3, Division 2, Chapter 1, Article 21, §646.1

This section requires that dirt or unpaved co rrals or ramps not be located closer than 25 feet from the milking barn or closer than 50 feet from the milk house. This section also provides minimum slope requirements for unpaved corrals and requires that all cow washing areas be paved and sloped to drain. None of the options in Rule 4570 would contradict these requirements.

5. CCR Title 3, Division 2, Chapter 1, Article 21, §659

This section requires that floor s, curbs, and gutters of the milking barn be constructed of concrete or other acceptable material and sl oped to a drain. No options in Rule 4570 would preclude this.

6. CCR Title 3, Division 2, Chapter 1, Article 21, §661

This section requires that r oof drainage from barns , milk houses, or shelters shall not

drain into a corral unless the corrals are paved and properly drained. No options in Rule 4570 would preclude this.

7. CCR Title 3, Division 2, Chapter 1, Article 21, §662

This section requires that the feed discharge area of bulk feed storage facilities shall be paved with concrete or equal material, curbed, and sloped to drain. No options in Rule 4570 would preclude this.

8. Regional Water Quality Board Dr aft Waste Discharge Requirements

The Regional Water Quality Board is drafting waste disc harge requirements (WDR) for

dairies. Since these will not be finalized prior to Rule 4570 adoption, staff can not conclusively determine that no conflicts will ex ist. However, as of 3/26/06, the draft of the waste discharge requirements did not c onflict with Rule 4570 requirements. The

differences between the rules are due to the di fferent goals, relevant science available, and jurisdictions of the agencies. The signi ficant difference between the two proposed

rules are:

• Definition of a confined animal facility

• WDR: facilities feeding by a me thod other than graz ing at any time.

• Rule 4570: facilities feed by a method other than grazing for at least 45 days. (Staff included the 45 day threshold becaus e it is included in the definition of a confined animal facility specified in CH&SC 40724, which is where the authority for the rule comes from).

• Applicability

• WDR: facilities with over 250 cattle are subject to the rule.

• Rule 4570: facilities with over 1,000 milk ers are subject to the rule (Staff usedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix E: Rule Consistency Analysis for Rule 4570 June 15, 2006

C-148 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 the threshold for a large CAF dete rmined by the ARB since the emission factor data for air, unlike for water, is not well est ablished; thus, staff does not believe they can make the determinati ons necessary to go below the ARB's large CAF definition.)

• Land application of solid manure

• WDR: facilities shall land incor porate within forty-eight (48) hours.

• Rule 4570: facilities shall land incor porate within seventy- two (72) hours. (Staff used seventy-two (2) hours to a cknowledge that the difference in VOC emissions from forty-eight (48) to seventy-two (72) hours for solid manure is minimal and acknowledge owners'/ operators' comments that land incorporation within forty- eight hours (48) would impose an excessive burden, but within seventy-two (72) hours would be feasible.)

• Land application of liquid manure

• WDR: facilities shall allow liquid manur e to stand in the fields no longer than seventy-two (72) hours after application.

• Rule 4570: facilities shall allow liquid manure to stand in the fields no longer than twenty-four (24) h ours after application. (The intent of Rule 4570 is to minimize the amount of time that liquid manure

can emit VOCs in an uncontrolled manner. Since stakeholders indicated that twenty-four (24) hours w ould be the minimal reasonab le time period, staff incorporated this time period into Rule 4570.)

It is important to mention that in case s where one agency's rules are more stringent than another agency's rules, affected source operators are obligated to comply with the most stringent regulatory requirements.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix E: Rule Consistency Analysis for Rule 4570 June 15, 2006

C-149 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-150 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

# APPENDIX F

AMMONIA REDUCTIONS ANALYSIS FOR PROPOSED RULE 4570 (CONFI NED ANIMAL FACILITIES)

June 15, 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-151 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 AMMONIA REDUCTION ANALYSIS

I. SUMMARY

Proposed Rule 4570 would requi re operators of Large Confin ed Animal facilities (CAF) to implement management practices or controls to reduce VOC emissions. CH&SC 40724.6(d) is clear on its applicability and does not mandate the District to regulate ammonia.

However, these practices and controls have an added bonus of also controlling ammonia (NH3) emissions from the CAF. Based on staff calculations approximately 103 to 131 tons per day (tpd) of NH 3 will be reduced by Rule 4570 requirements.

Emissions reductions are summarized in Table 1. Ammonia reductions were calculated according to the methodology expl ained later in this analysis. In making these calculations, staff assumed facilities would choose the lowest cost options to comply with the rule requirement.

Table 1: Summary of CAF Ammonia Reductions

Total NH 3 Emissions (tpd)

Ammonia Emissions from CAF 283 Ammonia Emissions from CAF that are exempt from rule requirements 65

Ammonia Emissions from CAF that are subject to rule requirements 218

Ammonia Reductions from proposed control requirements 103 to 131

Total Percent Reductions from CAF 36% to 46%

Table 2: Summary of CAF Ammonia Reductions by Animal Type

Total NH 3 Emissions (tpd) NH 3 Emissions from Large CAFs (tpd) NH 3 Reductions (tpd) Dairy 180 130 66 to 86

Beef Feedlot 9 8 4 to 5

Other Cattle 54 52 33 to 40

Swine 0.70 0.35 0 Poultry 39 28 0SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-152 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 II. INTRODUCTION

Since practices that reduce the rate of dec omposition or moisture in organic material

reduce both VOC and ammonia reductions most of the VOC mitigation measures also

reduce ammonia.

Staff assumed that the percent ages of the total VOC emissions attributable to each emission source are identical to the percent of total NH 3 emissions attributable to each

emission source. Since there is an assu med relationship between ammonia and VOC emissions, the percentages from Table 2: Summary of Emi ssion Units can be multiplied by the total ammonia emissions to determine the emissions from each emission unit. The following equation was utilized to develop the numbers in Table 3.

(VOC Emissions from Emission Unit) ÷ (Total VOC Emissions) x (Total NH 3 Emissions)=

NH 3 Emissions from Emission Unit.

Staff then made the fo llowing assumptions:

• The emission factor for beef is 33. 06 lbs/hd/yr based on "Ammonia and Gaseous Nitrogen Emissions from a Commercial beef Cattle Feed yard Estimated Using the

Flux Gradient Method and N: P Ration Anal ysis" in State of t he Science Animal Manure and Waste Management , Jan. 4-7, 2005.

• The emission factor for milking cows is 74.0 lbs/hd/yr based on ARB's preliminary determination;

• The percent of VOC emitted by each type of dairy animal compared to the VOC emitted by a milk cow is equi valent to the percent of NH 3 emitted by each type of dairy animal compared to the NH 3 emitted by a milk cow. The calculations are

below:

• NH 3 Emissions Non-Milker = VOC Emissions from Non-Milker ÷ VOC Emissions from Milker (21 lbs/hd/yr for freestall dairy) x NH 3 Emissions from Milk er (74 lbs/hd/yr).

• Therefore:

• NH 3 Dry Cow = 11.9 ÷ 21 x 74 = 40.93 lbs/hd/yr

• NH 3 Heifer 15-24 Mo. = 8.3 ÷ 21 x 74 = 29.25 lbs/hd/yr

• NH 3 Heifer 7-14 Mo = 7.2 ÷ 21 x 74 = 25.37 lbs/hd/yr

• NH 3 Heifer 4- 6 Mo = 6.6 ÷ 21 x 74 = 23.26 lbs/hd/yr

• NH 3 Calf 0-3 Mo = 6.2 ÷ 21 x 74 = 21.85 lbs/hd/yr

III. DAIRY EMISSION REDUCTION ANALYSIS

A. Dairy Emission Units

Ratios can be taken from VOC emissions at each emission unit, as shown in Table 3.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-153 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 * These emissions were not quantified in the initial det ermination of the emission factor, however, Dr. CE Schmidt in his "Assessment of Reactive Organic Ga ses and Amines from a Northern California Dairy Using the USEPA Surface Emission Isolation Flux Cham ber" presented to ARB Jan. 26, 2005 quantified these. Additionally, this assumes the worst-case sc enario for dairy emissions. Estimated dairy VOC emissions range from 19.3 lbs/hd/yr to 21.63 lbs/hd/ yr depending on factors such as whether or not the facility has a freestall. However, t he District's ammonia emission factor fo r lactating cows of 74 lb/hd/yr is constant regardless of the type of housing or facility infrastructure.

B. Dairy Inventory

The following table includes dairy milk and dr y cow numbers in the San Joaquin Valley, from a California Depart ment of Food and Ag ( CDFA) report entitled “ California Agricultural Statistics 2004 ”. These numbers only include m ilking and dry cows, not

heifers that have not calved or calves.

Table 4: Number of Milk and Dry Cows – CDFA 2004

County 2002 2003 2004 Projected

2005*
Fresno 86,115 90,345 95,577 99,878 Kern 85,830 98,478 121,147 126,599 Kings 146,545 153,475 162,656 169,976 Madera 49,899 57,099 63 ,934 66,811 Merced 224,895 224,734 237,854 248,557 San Joaquin 99,828 106,162 103,619 108,281 Stanislaus 164,558 177,432 178,420 186,449 Tulare 424,643 437,476 442,853 462,781 Total 1,282,313 1,345,201 1,406,060 1,469,333
*The growth from 2002 to 2003 was approximately 4.9% and the growth from 2003 to 2004 was 4.5%. In order to be conservative, staff assumed a growth of 4.5% for 2004 to 2005.

In order to estimate the number of support stock at a dairy, ratios were developed using 216 dairy applications submi tted to the District. Based on those applications the following ratios were developed. These rati os represent the number of each type of

animal. Table 3: Dairy Summary of Emission Units

Emission Unit VOC Emissions (lbs/hd/yr) % of Total VOC Emissions

1. Cow Housing- No n-enteric 4.8 22.2%

2. Milk Center- Non-enteric 0.2 0.9%

3. Enteric Emissions 8.3 38.4% 4. Liquid Manure Handling 2.7 12.5% 5. Land Application 5.0 23.1% 6. Solid Bedding Piles 0.63* 2.9%

TOTAL 21.63 100%SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-154 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Table 5: Ratio of Each Type of Dairy Cow to Milkers

Support

Animals to

Milkers Dry

Cows

to

Milkers Heifers (15- 24 mo) to

Milkers Heifers (7-14 mo) to

Milkers Heifers (4-6 mo) to

Milkers Calf (<4 mo) to

Milkers

107% 16% 34% 29% 16% 11%

Before the above ratios can be applied to the CDFA milk and dry cow numbers to estimate a total number of head, the dry cows first need to be subtracted from the milk and dry cow numbers. Based on the ratios above, 16% of cows are dry cows when compared to milk cows, therefore the ca lculations would be as shown below:

1,469,333/1.16 = 1,266,666 milk cows 1,266,666/0.16 = 202,667 dry cows 1,266,666/0.11 = 1,274,249 calves cows

Now we can use the ratios obtained above to es timate all the other types of cows at a dairy. Staff assumed, based on the ARB' s June 23, 2005 Staff Report for Confined Animal Facilities page iii that 72% of the dairy cows would be included in this regulation.

C. Dairy Reductions

Some of the control measures, such as feedi ng according to NRC, guidelines affect all

animals and emission sources at the facility. Other contro l measures, such as using a phototrophic lagoon, only affect s one emission source—the lagoo n. Additionally a few control measures only affect certain animals and emission sources, such as increased scraping of heifer areas. Table 8 shows each control measures; the number of animals it affects; types of animals it affects; emission sources it affects; reductions to that Total

Animals NH3 Factor (lb/hd/yr) from

Table 3 Total NH3

Emissions

(lb/yr) Animal

Included In

Rule NH3 Factor (lb/hd/yr) Total NH3

from Animals

Included in Rule (lb/yr)

Milk Cows 1,266,666 74.00 93,733,284 912,000 74.00 67,487,964 Dry Cows 202,667 40.93 8,295,160 145,920 40.93 5,972,515 Heifers (15-24) 430,667 29.25 12,597,010 310,080 29.25 9,069,847 Heifers (7-14) 367,333 25.37 9,319,238 264,480 25.37 6,709,852 Heifers (3-6) 202,667 23.26 4,714,034 145,920 23.26 3,394,105

Calves 139,333 21.85 3,044,426 100,320 21.85 2,191,987
Total Cows 2,609,333 131,703,153 1,878,720 94,826,270 Table 6: Total 2005 Dairy Animals in SJVABSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-155 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 source due to other controls used that have a cumulative affect, the control efficiency of the method, and the overall reduct ions. In Section D, staff explained the calculations in more detail. In general, the calculations are:

Total NH 3 = Animals Affected x Emission Factor

Reductions (Red) = Animals Affe cted (An. Af.) x Emission Fa ctor (EF) for animals in areas affected (Areas) x (1-Per cent Previously Controlled NH 3 (Prev. Cont)) x Control Efficiency of Control Measure (CE)

Option 1: Feed Adjustment

This measure assumes that the owner/operator will feed a ll his animals based on the most recent NRC guidelines.

Therefore, it would apply to all animals at the facility. Since it reduces the volatile organic compounds and precursors in the feed (feed pile emissions) and in the animals (manure and enteric emissions) staff believes that the control efficiency should be applied to all emission s at the facility.

SCAQMD Tetra Tech Report showed appr oximately 28% reduction in ammonia emissions from reducing the protein cont ent in feed by 4%. Studies on swine,

referenced in the draft st aff report, showed similar per centages of reduction from manipulation of the amount of crude protein in swine diets. Therefore, staff applied a 28% control efficiency for the low range. On beef cattle, "Feeding High Moisture Corn Instead of Dry Rolled Corn R educes Odor Production in Fi nishing Beef Cattle Manure Without Sacrificing Performance" by S.L. Archibeque et al us e of high moisture instead of dry rolled corn reduced emissions by 46% . Therefore, this was utilized for the high range of control efficiency.

Option 1 Reductions (low) = 28% Option 1 Reductions (high) = 46%

Option 2: Freestall Management Practices

Based on the CMP database, appr oximately 71% of the fac ilities have freestalls. Additionally, few calves are housed in freesta lls. Therefore, staf f assumed 71% of the animals other than calves would be affected by this control. Since the cleaning only applies to waste (feed and manur e) in the animal housing, the emission factor from Table 3 for Cow Housing-Not Enteric was utilized.

Staff assumed that the control efficiency fo r ammonia is approximately the same as the control efficiency of VOCs. Since the pr eliminary BACT showed a 47.7% VOC control efficiency for increased cleaning of freestalls, st aff assumed that, toget her, all activitiesSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-156 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 in Option 2 will achieve a 47.7% control e fficiency for the low estimate. The SCAQMD Tetra Tech Report showed 50% reductions, t herefore this was assumed for the high control efficiency.

Freestall emissions = 16.43 lb/hd/yr x 60% (emissions from freestall) = 9.86 lb/hd/yr from freestalls

Option 2 Low Reductions = 9.86 lb/hd/yr x 72% (emissions remaining after implementing Option 1) x 47.7% (c ontrol efficiency)= 3.39 lb/hd/yr Option 2 High Reductions = 9.86 lb/hd/yr x 54% (emissions remaining after implementing Option 1) x 50% (cont rol efficiency)= 2.66 lb/hd/yr

This is out of an emission factor of 74 lb/ hd/yr, but only affects 71 % of the facilities.

The low percent reducti on is 3.39 lb/hd/yr ÷ 74 lb/hd/yr x 71% = 3%

The high percent reduction is 2.66 lb/hd/yr ÷ 74 lb/hd/yr x 71% = 3%

Option 3: Corral Moisture Management Practices

South Coast AQMD Tetratech Report 50% VO C control efficiency for application of lime, one of the methods for minimizing mois ture in corrals. Staff assumed that, together, all activities to minimize moisture achieve 50% control efficiency for the low range. "Dairy Manure Additives" by Everett D. Thomas published by William H. Miner Agricultural Research Institute found a 65% reduction in ammonia due to application of lime. Therefore, this was ut ilized for the high estimates.

Corral emissions = 16.43 lb/hd/yr x 40% (emissions from corrals) = 6.57 lb/hd/yr from corrals

Option 3 Low Reductions = 6.57 lb/hd/yr x 72% (emissions remaining after implementing Option 1) x 50% (cont rol efficiency)= 2.36 lb/hd/yr Option 3 High Reductions = 6.57 lb/hd/yr x 54% (emissions remaining after implementing Option 1) x 65% (cont rol efficiency)= 2.66 lb/hd/yr

This is out of an emissi on factor of 74 lb/hd/yr.

The low percent reducti on is 2.36 lb/hd/yr ÷ 74 lb/hd/yr= 3%

The high percent reduction is 2.31 lb/hd/yr ÷ 74 lb/hd/yr= 3%

Option 4: Corral CleaningSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-157 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Since this increases the frequency by 50%, staf f assumes that it r educes the emissions by 50%. Corral emissions = 16.43 lb/hd/yr x 40% (emissions from corrals) = 6.57 lb/hd/yr from corrals

Option 4 Low Reductions = 6.57 lb/hd/yr x 72% (emissions remaining after implementing Option 1) x 97% (emissions remaining after Option 3) x 50% (control efficiency)= 2.29 lb/hd/yr

Option 4 High Reductions = 6.57 lb/hd/yr x 54% (emissions remaining after implementing Option 1) x 97% (emissions re maining after Option 3) x 50% (control efficiency)= 1.72 lb/hd/yr

This is out of an emissi on factor of 74 lb/hd/yr.

The low percent reducti on is 2.29 lb/hd/yr ÷ 74 lb/hd/yr= 3% The high percent reduction is 1.72 lb/hd/yr ÷ 74 lb/hd/yr= 2%

Option 5: Milk Parlor

Staff assumed that this was in cluded in the baseline; theref ore, no additiona l reductions are expected.

Option 6: Lagoon Management

This option assumed that owner/operators will:

• Utilize a phototrophic lagoon systems or

• Utilize a solid separator system prior to sending waste into the lagoon.

The following assumptions were made:

• Since several articles correlate reduc ed lagoon loading with VOC emissions and promotion of phototrophic cond itions, staff assumed that the control efficiency for a phototrophic lagoon was similar to that of a lagoon system with a solid separator.

• Since Do and Zahn (see reference in the staff report) fo und an 80-90% reduction in VOCs from a swine facility staff with a phototrophic system conservative
assumed an 80% reduction in ammonia from a swine facility with a phototrophic lagoon.

• Wolves, Bears, and their Prey in Ala ska: Biological and Social Challenges in Wildlife Management by the National Resear ch Council published by the National Academy Press in 1997, in addition to ot her publications show a correlation between the quantity of food in a biosyst em and the quantity of organisms. Therefore, although th ere is more nitrogen in a dair y lagoon than a swine lagoon,SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-158 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 staff would assume the popul ation of microorganisms consuming the nitrogen would increase to match the supply. T herefore the control efficiency between a swine and dairy lagoon woul d be similar—80% to 90%

Option 6 Low Reductions = 9.25 lb/hd/yr x 72% (emissions remaining after implementing Option 1) x 80% (c ontrol efficiency)= 5.33 lb/hd/yr Option 6 High Reductions = 9.25 lb/hd/yr x 54% (emissions remaining after implementing Option 1) x 90% (cont rol efficiency)= 4.50 lb/hd/yr

This is out of an emissi on factor of 74 lb/hd/yr.

The low percent reducti on is 5.33 lb/hd/yr ÷ 74 lb/hd/yr= 7%

The high percent reduction is 4.50 lb/hd/yr ÷ 74 lb/hd/yr= 6%

Option 7: Land Application

This option assumed that owner/operators will:

• Rapidly land incorporate the manure;

• Only apply manure that has been anaerobically treated; and

• Only apply manure with moisture less than 50%.

In order to be conservative st aff assumed that use of cont rol measures affecting animal waste prior to the waste being land applied have a cumulative effect. SCAQMD noted a range of 42% to 50% for control efficiency.

Option 7 Low Reductions = 17.09 lb/hd/yr x 72% (emissions remaining after implementing Option 1) x 42% (cont rol efficiency)= 5.17 lb/hd/yr Option 7 High Reductions = 17.09 lb/hd/yr x 54% (emissions remaining after implementing Option 1) x 50% (cont rol efficiency)= 4.61 lb/hd/yr

This is out of an emissi on factor of 74 lb/hd/yr.

The low percent reducti on is 5.17 lb/hd/yr ÷ 74 lb/hd/yr= 7% The high percent reduction is 4.61 lb/hd/yr ÷ 74 lb/hd/yr= 6%

Total Reduction

The total reductions are 51% to 66% which is

Total Reductions = 94,826,270 lb/hd/ yr x 51% = 48,361,397 lb/hd/yr Total Reductions = 94,826,270 lb/hd/ yr x 66% = 62,585,338 lb/hd/yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-159 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 IV. BEEF EMISSION REDUCTION ANALYSIS

A. Beef Emission Units

Ratios can be taken from the VOC emissi ons at each emission unit, as shown below.

* These emissions were not quantified in the in itial determination of the emission factor, however, Dr. CE Schmidt in his "Assessment of Reactive Organic Gases and Amines from a Northern California Dairy Using t he USEPA Surface Emission Isolation Flux Chamber" presented to ARB J an. 26, 2005 quantified these.

B. Beef Inventory

The CAF head counts are from the California Department of Food and Agriculture survey. These were multiplied by the emis sion factor to estimate the total ammonia

emissions.

Table 8: Total Beef and Other Cattle in the SJVAB

Head in

Fresno Head in

Kern Head in Kings Head in

Madera Head in

Merced Head in

San
Joaquin Head in

Stanislaus Head in

Tulare Total

Head Emission

Factor from

Table 3 Total NH3 (lbs/hd/yr

Total Beef 22,000 34,000 5,000 14,000 27,000 18,000 39,000 29,000 188,000 33.06 6,215,280

Beef at
Large

CAF 20,900 32,300 4,750 13,300 25,650 17,100 37,050 27,550 178,600 33.06 5,904,516 Table 7: Beef Summary Emission Units

Emission Unit VOC

Emissions (lbs/hd/yr) % of Total VOC Emissions

1. Cow Housing- Non-enteric 3.3 30%

2. Enteric Emissions 5.2 47% 3. Land Application 2.5 23% 4. Solid Bedding Piles 0.1* 1%

TOTAL 11.1 100%SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-160 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 C. Beef Reductions

Some of the control measures, such feeding according to NRCS, guidelines affect all animals and emission sources at the facility. Other control measures, such using a phototrophic lagoon, only affect s one emission source—the lagoo n. In Section D staff explained the calculations in more deta il. In general the calculations are:

Total NH 3 = Animals Affected x Emission Factor Reductions (Red)= Animals Affected (An. Af.) x Emission Factor (EF) for animals in areas affected (Areas) x (1-Per cent Previously Controled NH 3 (Prev. Cont)) x Control Efficiency of Control Measure (CE)

Staff assumed that the contro l efficiencies for each practi ce for the dairy were the

same for beef.

Option 1: Feed Adjustment

This measure assumes that the owner/operator will feed a ll his animals based on the most recent NRC guidelines.

Therefore, it would apply to all animals at the facility. Since it reduces the volatile organic compounds and precursors in the feed (feed pile emissions) and in the animals (manure and enteric emissions) staff believes that the control efficiency should be applied to all emission s at the facility.

SCAQMD Tetra Tech Report showed appr oximately 28% reduction in ammonia emissions from reducing the protein cont ent in feed by 4%. Studies on swine,

referenced in the draft st aff report, showed similar per centages of reduction from manipulation of the amount of crude protein in swine diets. Therefore, staff applied a 28% control efficiency for the low range. On beef cattle, "Feeding High Moisture Corn Instead of Dry Rolled Corn R educes Odor Production in Fi nishing Beef Cattle Manure Without Sacrificing Performance" by S.L. Archibeque et al us e of high moisture instead of dry rolled corn reduced emissions by 46% . Therefore, this was utilized for the high range of control efficiency.

Option 1 Reductions (low) = 28% Option 1 Reductions (high) = 46%

Option 2: Corral Moisture Management Practices

South Coast AQMD Tetratech Report 50% VO C control efficiency for application of lime, one of the methods for minimizing mois ture in corrals. Staff assumed that, together, all activities to minimize moisture achieve 50% control efficiency for the lowSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-161 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 range. "Dairy Manure Additives" by Everett D. Thomas published by William H. Miner Agricultural Research Institute found a 65% reduction in ammonia due to application of lime. Therefore, this was ut ilized for the high estimates.

Option 2 Low Reductions = 3.3 lb/hd/yr x 72% (emissions remaining after implementing Option 1) x 50% (control efficiency)= 1.19 lb/hd/yr

Option 2 High Reductions = 3.3 lb/hd/yr x 54% (emissions remaining after implementing Option 1) x 65% (control efficiency)= 1.16 lb/hd/yr

This is out of an emission factor of 11.1 lb/hd/yr.

The low percent reducti on is 1.19 lb/hd/yr ÷ 11.1 lb/hd/yr= 11%

The high percent reduction is 1.16 lb/hd/yr ÷ 11.1 lb/hd/yr= 10%

Option 3 : Corral Cleaning

Since this increases the frequency by 50%, staf f assumes that it r educes the emissions by 50%.

Option 3 Low Reductions = 3.3 lb/hd/yr x 72% (emissions remaining after implementing Option 1) x 89% (emissions remaining after Option 2) x 50% (control efficiency)= 1.06 lb/hd/yr

Option 3 High Reductions = 3.3 lb/hd/yr x 54% (emissions remaining after implementing Option 1) x 90% (emissions remaining after Option 3) x 50% (control efficiency)= 0.80 lb/hd/yr

This is out of an emission factor of 11.1 lb/hd/yr.

The low percent reducti on is 1.06 lb/hd/yr ÷ 11.1 lb/hd/yr= 10% The high percent reduction is 0.80 lb/hd/yr ÷ 11.1 lb/hd/yr= 7%

Option 4 : Land Application

This option assumed that owner/operators will:

• Rapidly land incorporate the manure;

• Only apply manure that has been anaerobically treated; and

• Only apply manure with moisture less than 50%.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-162 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 In order to be conservative st aff assumed that use of contro l measures affecting animal waste prior to the waste being land applied have a cumulative effect. SCAQMD noted a range of 42% to 50% for control efficiency.

Option 4 Low Reductions = 2.5 lb/hd/yr x 72% (emissions remaining after implementing Option 1) x 42% (control efficiency)= 0.76 lb/hd/yr

Option 4 High Reductions = 2.5 lb/hd/yr x 54% (emissions remaining after implementing Option 1) x 50% (control efficiency)= 0.68 lb/hd/yr

This is out of an emission factor of 11.1 lb/hd/yr.

The low percent reducti on is 0.76 lb/hd/yr ÷ 11.1 lb/hd/yr= 7% The high percent reduction is 0.68 lb/hd/yr ÷ 11.1 lb/hd/yr= 6%

Total Reduction

The total reductions are 56% to 69% which is

Total Reductions = 5,904,516 lb/hd/ yr x 51% = 3,011,303 lb/hd/yr Total Reductions = 5,904,516 lb/ hd/yr x 66% = 3,896,981 lb/hd/yr

IV. OTHER CATTLE EMISSION REDUCTION ANALYSIS

A. Other Cattle Inventory and Emissions

Table 9: Other Cattle in the SJVAB

Head in

Fresno Head in

Kern Head in Kings Head in

Madera Head in

Merced Head in

San
Joaquin Head in

Stanislaus Head in

Tulare Total Head Emission

Factor from

Table 3 Total NH3 (lbs/hd/yr

Total Other

Cattle 295,000 145,000 114,000 78,000 215,000 98,000 213,000 447,000 1,605,000 24.90 39,964,500

Other Cattle at Large CAF 280,250 137,750 108,300 74,100 204,250 93,100 202,350 424,650 1,524,750 24.90 37,966,275

B. Other Cattle Reductions A significant number of these animals ar e being raised for replacement animals on dairies, as veal, or as stock for beef feedlot s. There is limited scientific data for this source. Therefore, since these animals are not producing milk and ar e closer in age to beef cattle than lactating cows , the control efficiencies of mitigation measures are

assumed identical to that of beef cattle. In cases where there is no similar controlSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix F: Ammonia Reduction A nalysis for Rule 4570 June 15, 2006

C-163 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 measure for beef cattle, the control efficienc y for the most similar dairy mitigation

measure was used.

Option 1: Feed Adjustment

Option 1 Reductions (low) = 28% from beef data Option 1 Reductions (high) = 46% from beef data

Option 2: Housing Moisture Management Practices

Option 2 Reductions (low) = 11% from beef data Option 2 Reductions (high) = 10% from beef data

Option 3: Housing Cleaning

Option 3 Reductions (low) = 10% from beef data Option 3 Reductions (high) = 7% from beef data

Option 4: Liquid Manure

Option 4 Reductions (low) = 7% from dairy data Option 4 Reductions (high) = 8% from dairy data

Option 5 : Land Application

Option 5 Reductions (low) = 7% from beef data Option 5 Reductions (high) = 6% from beef data

Total Reduction

The total reductions are 63% to 77% which is

Total Reductions = 37,966,275 lb/hd/ yr x 63% = 23,918,753 lb/hd/yr Total Reductions = 37,966,275 lb/hd/ yr x 77% = 29,234,032 lb/hd/yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C-164 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

# APPENDIX G

ENVIRONMENTAL ANALYSIS PROPOSED RULE 4570 (CONFI NED ANIMAL FACILITIES)

June 15, 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C-165 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT



### Initial Study/Environmental Checklist

Rule 4570 (Confined Animal Facilities)

Public Review Period Begins: April 27, 2006

Public Review Period Ends: May 29, 2006 at 5:00 P.M.

A. PROJECT BACKGROUND INFORMATION

1. Project Title: Rule 4570 (Confined Animal Facilities)

2. Lead Agency Name and Address

San Joaquin Valley Unified Air Poll ution Control District (District) 1990 E. Gettysburg Ave. Fresno, CA 93726

3. Contact Person:

CEQA: Ms. Debbie Johnson Rule: Ms. Lucinda Roth (559) 230-5800 (559) 230-5800

4. Project Location:

This Rule applies to any c onfined animal facility locat ed within the boundaries of the San Joaquin Valley Unified Ai r Pollution Control District (see Exhibit 1, Map of District boundaries).

5. Project Sponsor’s Name and Address:

San Joaquin Valley Unified Ai r Pollution Control District 1990 E. Gettysburg Ave. Fresno, CA 93726

6. Description of Project:

This Initial Study is based on Draft Rule 4570, dated March 13, 2006. The draft Rule is

intended to reduce emissions of volatile organic compounds (VOC) from confined

animal facilities. Annual VOC emissions from confined animal facilities are estimated to be over 27,000 tons per year. Averaged over 365 days, daily emissions are over 70 tons per day. Confined animal facility em issions are temperat ure dependent with theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C-166 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 highest emissions occurring during the summ er when the SJVUAPCD experiences the largest number of exceedances of the Federal health based ozone standards.

Rule 4570 fulfills a control measure commi tment in the 2004 Extreme Ozone Attainment Demonstration Plan, and meet s the requirements of State Senate Bill (SB) 700, and the Reasonably Available Control Technology (RAC T) provisions of the Federal Clean Air Act (CAA). Under SB 700, Confin ed Animal Facilities (CAFs) that exceed the California Air Resources Board (ARB) definition of a “large CAF” must install Best Available Retrofit Control Technology (BARCT) to r educe their VOC emissions. CAA section 182(b)(2) requires existing facilities that exc eed the federal major source thresholds to implement Reasonably Availabl e Control Technology (RACT). The RACT threshold is currently 10 tons/year in the San Joaquin Valle y. For the purposes of this rule the control requirements for state BARCT and federal RACT are the same.

There were over 6,000 CAFs operating in the San Joaquin Valley Air Basin (SJVAB) in 2002. Of these facilities, the District esti mates that somewhat less than half will be subject to the rule’s control requirements. Other smaller CAFs will be subject only to record keeping requirements to verify their exemption from the ru le. New CAFs that exceed 1⁄2 of the District’s major source thre shold (12.5 tons/year) from Rule 2201 are required to implement the Best Available Control Technology (BACT), which is generally more stringent than RACT and BARCT. Theref ore, these large ne w sources will meet or exceed Rule 4570 by implem enting controls required duri ng the District’s new source review permitting process.

Draft Rule 4570 incorporates a cafeteria-bas ed approach that would require each large

CAFs to reduce their baseline uncontroll ed emissions by approximately 30% annually. This would equate to annual emission reducti ons of approximately 6,570 tons, for a daily reduction of approximately 18 tons per day. Each CAF's emissions baseline would be established by multiplying the District emi ssion factor for each type of animal by the number of that type of animal on the facility. Operators w ould have the flexibility to comply with the Rule using any combinat ion of the following emission reduction

measures:

A. Feed and silage management practices such as: using feed formulation practices; increased feed removal and cleaning practice s; feed and silage storage practices;

and others.

B. Increased cleaning of the m ilk parlor, where applicable.

C. Increased cleaning frequency in va rious areas of animal housing.

D. Minimization of moisture in various areas of animal housing.

E. Use of manure additives in corrals or pens.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C-167 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 F. Management practices for storing manur e and separated solids such as: covering dry manure piles, removing manure from th e facility; use of a digester; and others.

G. Management practices for lagoons such as: minimization of animal waste in lagoons; use of anaerobic treatment lagoons; use of a solid separator; and others.

H. Management practices for land applicat ion of animal waste such as: land incorporate all solid manur e within seventy-two (72) hours; only apply waste that has been anaerobically tr eated; minimize moisture cont ent of solid manure that is land applied; and others. Design lagoons and load la goons according to National Resource Conservation Service (NRCS) guidelines.

I. House animals in enclosures that are v ented to control devices with VOC control

efficiencies of at least 80%.

Please refer to Draft Rule 4570 and draft staff report which are availa ble at the District’s

website at www.valleyair.org/workshops/public_workshops_idx.htm for a detailed discussion of the provisions of the draft rule.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C-168 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 San Joaquin Valley Unified air Pollution Control District BoundariesSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C-169 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 The Rule provides operators flexibility to pursue the most cost e ffective strategy for reducing their emissions. Given the cost di fferential between installing VOC controls on lagoons or enclosing their housing and pursuing emissions reductions elsewhere, it is unlikely that the industry will install VOC cont rols on lagoons or enclose housing. The most likely approach for complying with Ru le 4570 is operators will mitigate emissions by feeding according to NRC guidelines; incr eased cleaning and removal of spilled feed; increased cleaning of animal housing and milk parlors, covering of dry manure piles; use of solid separation devices or phototr ophic lagoons; and rapid l and incorporation of

manure.

7. Other Agencies Whose Approvals Is Required and Permits Needed:

Modified and new dairies may require permits from the R egional Water Quality Control Board, California Integrated Waste Manage ment Board, and counties. No other agencies have discretionary authority over this project. The United States Environmental Protection Agency must also approve the Rule.

8. Project Compatibility wi th Existing Zones and Plans:

Adoption of this Rule will not a ffect any land use zones or plans.

9. Name of Person Who Prepared Initial Study:

Ms. Lucinda Roth Air Quality SpecialistSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C-170 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570

B. ENVIRONMENTAL FACTOR S POTENTIALLY AFFECTED

The environmental factors checked below woul d be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages.

Aesthetics Agriculture

Resources Air Quality

Biological Resources Cultural Resources Geology /Soils

Hazards & Hazardous

Materials Hydrology / Water Quality Land Use / Planning

Mineral Resources Noise Population / Housing

Public Services Recreation Transportation/Traffic

Utilities / Service Systems Mandatory Findings of SignificanceSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C-171 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 DETERMINATION: (To be completed by the Lead Agency)

On the basis of this initial evaluation:

X I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as de scribed on attached sheets. An ENVIRONMENTAL IMPACT REPORT is requir ed, but it must analyze only the

effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially signif icant effects (a) have been analyzed adequately in an earlier EIR or NE GATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are impo sed upon the proposed project, nothing further is required.

Signature: Date:

Printed Name: Lucinda Roth Title: Air Quality SpecialistSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 171 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

### D. ENVIRONMENTAL IMPACT CHECKLIST

Explanations of all answers on the c hecklist are located in section E.

Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

I. AESTHETICS -- Would the project:

a) Have a substantial adverse effect on a

scenic vista? X

b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? X

c) Substantially degrade the existing visual character or quality of the site and its surroundings? X

d) Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area? X

II. AGRICULTURE RESOURCES : In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project:

a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of theCalifornia Resources Agency, to nonagricultural use? X

b) Conflict with existing zoning for agricultural use, or a Williamson Act

contract? X

c) Involve other changes in the existing environment, which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 172 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

III. AIR QUALITY -- Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:

a) Conflict with or obstruct implementation of the applicable air quality plan? X

b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? X

c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions, which exceed quantitative thresholds for ozone precursors)? X

d) Expose sensitive receptors to substantial pollutant concentrations? X

e) Create objectionable odors affecting a substantial number of people? X

IV. BIOLOGICAL RESOURCES -- Would the project:

a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special stat us species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game

or U.S. Fish and Wildlife Service? X

b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or

US Fish and Wildlife Service? X

c) Have a substantial adverse effect on federally protected wetlands as defined by

Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological in terruption, or other

means? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 173 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of nativ e wildlife nursery

sites? X

e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or

ordinance? X

f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? X

V. CULTURAL RESOURCES -- Would the project:

a) Cause a substantial adverse change in the significance of a historical resource as

defined in '15064.5? X

b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to '15064.5? X

c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? X

d) Disturb any human remains, including

those interred outside of formal cemeteries? X

VI. GEOLOGY AND SOILS -- Would the project:

a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: X

i) Rupture of a known earthquake fault,as delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map issued by the State Geologist for the

area or based on other substantial

evidence of a known fault? Refer to Division of Mines and Geology Special

Publication 42. XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 174 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

ii) Strong seismic ground shaking? X

iii) Seismic-related ground failure, including liquefaction? X

iv) Landslides? X

b) Result in substantial soil erosion or the loss of topsoil? X

c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? X

d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? X

e) Have soils incapable of adequately supporting the use of septic tanks or

alternative wastewater disposal systems

where sewers are not available for the disposal of wastewater? X

VII. HAZARDS AND HAZARDOUS MATERIALS -- Would the project:

a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous

materials? X

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials

into the environment? X

c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 175 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the

environment? X

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? X

f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? X

g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? X

h) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or

where residences are intermixed with

wildlands? X

VIII. HYDROLOGY AND WATER QUALITY -- Would the project:

a) Violate any water quality standards or waste discharge requirements? X

b) Substantially deplete groundwater supplies or interfere substantially with recharge such that there would be a net deficit in aquifer volume or lower the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing uses or planned uses for which permits have been granted)? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 176 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

c) Substantially alter the existing drainage pattern of the site or area, including through

the alteration of the course of a stream or river, in a manner, which would result in

substantial erosion or siltation on- or off-site? X

d) Substantially alter the existing drainage pattern of the site or area, including through

the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner, which would result in flooding on- or off-site? X

e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? X

f) Otherwise substantially degrade water quality? X

g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? X

h) Place within a 100-year flood hazard area structures, which would impede or redirect

flood flows? X

i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of

a levee or dam? X

j) Inundation by seiche, tsunami, or

mudflow? X

IX. LAND USE AND PLANNING - Would the project:

a) Physically divide an established community? X

b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental

effect? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 177 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

c) Conflict with any applicable habitat conservation plan or natural community conservation plan? X

X. MINERAL RESOURCES -- Would the project:

a) Result in the loss of availability of a known

mineral resource that would be of value to the region and the residents of the state? X

b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? X

XI. NOISE B Would the project result in:

a) Exposure of persons to or generation of

noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? X

b) Exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? X

c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? X

d) A substantial temporary or periodic

increase in ambient noise levels in the project vicinity above levels existing without the project? X

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? X

f) For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to

excessive noise levels? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 178 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

XII. POPULATION AND HOUSING -- Would the project:

a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? X

b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? X

c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? X

XIII. PUBLIC SERVICES

a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:

Fire protection? X

Police protection? X

Schools? X

Parks? X

Other public facilities? X

b) Cumulatively exceed official regional or local population projections? X

c) Induce substantial growth in an area either directly or indirectly (e.g., through projects in an undeveloped area or extension of major

infrastructure? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 179 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

d) Displace existing housing, especially affordable housing? X

XIV. RECREATION

a) Would the project increase the use of existing neighborhood and regional parks or

other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? X

b) Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the

environment? X

XV. TRANSPORTATION/TRAFFIC -- Would the project:

a) Cause an increase in traffic, which is substantial in relation to the existing traffic load and capacity of the street system (i.e.,

result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? X

b) Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways? X

c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? X

d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? X

e) Result in inadequate emergency access? X

f) Result in inadequate parking capacity? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 180 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Potentially Significant

Impact Less Than Significant with Mitigation Incorporation Less Than Significant

Impact No Impact

g) Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? X

XVI. UTILITIES AND SERVICE SYSTEMS --Would the project:

a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? X

b) Require or result in the construction of

new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant

environmental effects? X

c) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant

environmental effects? X

d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded

entitlements needed? X

e) Result in a determination by the wastewater treatment pr ovider which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing

commitments? X

f) Be served by a landfill with sufficient permitted capacity to accommodate the project's solid waste disposal needs? X

g) Comply with federal, state, and local statutes and regulations related to solid

waste? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 181 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570

XVII. MANDATORY FINDINGS OF SIGNIFICANCE

a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? X

b) Does the project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively

Considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? X

c) Does the project have environmental effects, which will cause substantial adverse effects on human beings, either directly or indirectly? XSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 182 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 E. ENVIRONMENTAL IMPACT CHECKLIST COMMENTS

I. Aesthetics

There will be no significant adverse aes thetic impacts from Draft Rule 4570 (Confined Animal Facilities) because pot entially affected sites are already developed as confined animal facilities and any aesthetic impact would already exist. New sites subject to the provisio ns of Draft Rule 4570 would incorporate any necessary equipment into the design to minimize potential aesthetic impacts in accordance with local agency standar ds. Draft Rule 4570 would not create aesthetically offensive sites visible to the public. Draft Rule 4570 would not create a new source of substantial light or glar e, which would have a significant adverse effect on day or nighttime views in pot entially effected sites. No significant adverse aesthetic impacts are anticipated.

II. Agriculture Resources

Most of the potentially affected sites are exclusively devoted to agricultural use so there will be no direct significant adverse impact. Any additional infrastructure will be related to agricultural production and in many cases is a modification of an existing structure such as a lagoon.

In the event that a potentially affected si te chooses to install VOC control systems on their confined animal facility, the syst ems will likely occupy a maximum of 4,000 square feet for the largest sites and smaller areas for smaller facilities. The affected site owner/operator retains the opt ion to determine specifically where to install the VOC control systems. Options are also available for the affected site owner/operators to choose VOC control opt ions that do not occupy any space, such as increased flushing. Therefore, selecting a site devoted to agriculturally productive land for installation of a VOC control system or use of a VOC control that will occupy space inst ead of a management practice will be a decision resting solely upon the potentially a ffected site owners/operators.

Draft Rule 4570 will not result in a subs tantive conversion of prime or unique farmland to non-agricultural use. As not ed above, installing a VOC control system on a site devoted to agriculturally productive land will be a decision resting solely upon the potentially affected si te owners/operators and in any case would require very small amounts of land. Since the dairy is an agricultural us e, there will be no impact or conflict with existing zoning fo r agricultural use, or Williamson Act

contract.

III. Air Quality

The San Joaquin Valley Air Basin (SJVAB) is classified as an serious ozone

nonattainment area and a serious PM10 nonatta inment area for the health-based air quality standards established by the federal Clean Air Act. The SJVAB is also classifiedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 183 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 as severe nonattainment fo r the California ozone standard and nonattainment for the California PM10 standard. VOC is a precurso r of both ozone and to some extent PM10. It is expected that Draft Rule 4570 will result in reductions of VOC air emissions of approximately 18 tons per day annually. The net decrease in air emissions associated with operation of an approved em issions control device or management practice will result in a positive air quality benefit.

Draft Rule 4570 will not violate any air qua lity standard, result in a cumulatively considerable net increase in any criteria pollutant, expose sensitive receptors to substantial pollutants, or create any objectionable odors.

IV. Biological Resources

Implementing the provisions of Draft Rule 4570 will not have a signif icant adverse effect on the habitat of sensitive species, ripari an areas, federally protected wetlands, or interfere with any migratory fish or wildlife species with established migratory corridors. Draft Rule 4570 will not conflict with any lo cal policies or ordinances protecting biological resources or conflict with any H abitat Conservation Plan. No additional significant adverse impacts to biological re sources are expected to result from Draft Rule 4570 because it is expected to affect only agricultural/commercial areas where biological resources ar e already disturbed.

V. Cultural Resources

Effects from implementing Draft Rule 4570 will occur at existing potentially affected facilities generally located in agr icultural/commercial areas. As a result, significant adverse impacts on cultural re sources including: historical resources, archaeological resources, paleontological resources, geologic features, or the disturbance of any human remains is highly unlikely. Implementing the provisions of Draft Rule 4570 would not include any substantial excavation. Any new facilities subject to the Rule that are c onstructed in the future will go through a local agency approval and in most count ies an environmental review process where screening for cultural re sources would be addressed.

VI. Geology and Soils

Draft Rule 4570 provides an option for some owners/operators to in stall VOC controls

on their facilities. Installation of VOC c ontrols on existing sources could result in modifications to the existing facilities to accommodate additional control equipment. Modification of an existing si te is expected to constitute the most extreme compliance strategy. Draft Rule 4570 contains a provis ion for additional scraping of drylots that could require disruption or over-covering of soil, minor changes in topography or surface relief features, or a change in existing siltati on rates. Typically, scraping is needed to keep the manure pack from building up and does not cause a change to the underlying soil. Scraping drylots is a common managem ent practice; therefore no new impacts areSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 184 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 expected. Implementing the pr ovisions of Draft Rule 4570 will not increase the exposure of people of property to geologic hazards.

VII. Hazards and Hazardous Materials

Owners/Operators may elect to install and operate VOC emission s control systems. These systems would most likely consist of ductwork used to collect emissions and transport them to an emissions control devic e. These are established technologies and employed in other industries. Owners/Operators must co mply with federal, state, and local safety and environmental regulatio ns. Existing regulations are considered adequate to minimize significant worker ex posure and potential environmental hazards.

Draft Rule 4570 will not result in a significant adverse impact to hazard and hazardous

materials.

VIII. Hydrology and Water Quality

Affected sites are zoned for agricultural uses. In the event that a potentially affected site chooses to install VOC control systems on their facilities, the systems will occupy a maximum of 4,000 square for the largest site s and smaller areas for smaller facilities. The potentially affected site retains the option of where it will specific ally install the VOC control systems, thus selecting a site wit hin the 100-year flood zone will be a decision by the site owners/operat ors and the local agency issuing a building permit for construction of the equipment and must comp ly with the regulations of the Regional Water Quality Control Board. Use of additi onal water for flushing or control devices on lagoons are a few of many c ontrol options available to si te owners/operators. Water application to crops must be accomplished at rates that do not result in excessive nutrients impacting groundwater and surface water. The majority of the facilities recycle flush water; therefore additional flushing wo uld not result in significant increases in

water use at the facilities.

Draft Rule 4570 will not result in a signifi cant adverse impact to hydrology nor water quality will be significantly advers ely impacted by the proposed project

IX. Land Use and Planning

There are no provisions in Dra ft Rule 4570 that would affect land use plans, policies, or regulations. It is also expected that Dr aft Rule 4570 will not affect infrastructure development or require changes to exis ting zone designations because the draft provisions primarily regulate existing facilities. Local gov ernments determine land use and other planning considerations, and no la nd use or planning requirements will be altered. Therefore, present or planned land uses in the r egion will not be result in a significant adverse impact as a result of Draft Rule 4570.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 185 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 X. Mineral Resources

The implementation of Rule 4560 will take place at existing dairies, so there will be no new impacts on mineral resources. No significant adverse impacts on mineral resources are anticipated. Futu re sites subject to the rule will be evaluated for Mineral Resources impacts as part of the review process for new developments regularly undertaken by agencies with la nd use authority.

XI. Noise

A facility selecting to implement the retrofit ting provisions of Draft Rule 4570 is not expected to result in significant noise impacts. The affected facilities operate in agricultural/commercial settings where operational noise levels are already established and the resident human population is low. Any increas e in noise associated with the installation of add-on control equipment is expected to be minor. Any increase in noise associated with operation of add-on control equi pment is expected to be negligible. Noise levels will remain below significant levels and no si gnificant adverse impac ts are anticipated.

XII. Population and Housing

There are no provisions in Dr aft Rule 4570 that would resu lt in the creation of any industry that would significantly affect popul ation growth, or directly or indirectly induce significant construction of single- or multiple-fam ily units. No significant population relocation or growth inducement is expected from implementation of Draft Rule 4570. No significant adverse impacts are anticipated.

XIII. Public Services

Draft Rule 4570 does not mandate any change in facilities, or installation and operation of any control devic e or system that would resu lt in a substantial change or significant adverse impact on existing de mands for public services. Draft Rule 4570 will not result in significant adver se effects on fire protection, police protection, schools, parks, or other public facilities.

XIV. Recreation

Implementing the provisions of Draft Rule 4570 is not expected to adversely affect or change recreational facilities and resour ces in the District. No significant adverse aesthetic or recreation impacts are expected from implementing the provisions of Draft Rule 4570.

XV. Transportation/Traffic

Draft Rule 4570 will not increase the number of confined animal facilities operating in

the District and the amount of commodities produced at each farm will not increase. The existing facilities are located in ex isting agricultural/commercial areas where deliveries and commodity hauling are routine. As a result Draft Rule 4570 will not causeSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 186 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 a substantial increase in t he number of transport trips to confined animal facilities delivering raw materials or operational supp lies. Future sites will be evaluated for Transportation/Traffic impacts as part of t he review process for new developments regularly undertaken by agenc ies with land use authority.

XVI. Utilities and Service Systems

The provisions of Draft Rule 4570 will not result in exceedences of wastewater treatment requirements or require that new wastewater treat ment facilities be

built. Construction of new storm wate r drainage facilities will not be required. Draft Rule 4570 is not expected to require expansion of water supply systems. Waste disposal needs will not increase sign ificantly as a result of meeting the requirements of the rule.

Controlling VOC emissions from CAFs coul d require increased flushing, however the water is typically reused, therefore no signific ant net increase in water use is expected.

Draft Rule 4570 does not mandates contro l of waste disposal systems, nor impose control system designs. Operati onal practices are discretionary and are not mandated by the rule. Therefore, impl ementing the provisions of Draft Rule 4570 are not expected to result in signifi cant adverse impacts on existing water resources or the need to explore new water resources.

Facilities selecting to install VOC cont rol systems may be required to comply with requirements of the Regional Water Quality Control Board (RWQCB). Site by site evaluations will determine if potentially affect ed sites must receive approvals from the
RWQCB in the form of General Stormwat er Permits for Construction and Industrial Activities, Waste Discharge Permit, preparati on of a Storm Water Pollution Prevention Plan, or other permit or plan.

XVII. Mandatory Findings of Significance

This project does not have the potential to degrade the qua lity of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self su staining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the r ange of a rare or endangered plant or animal, or eliminate important examples of the major peri ods of California history or prehistory.

This project does not have t he potential to achieve short- term, to the disadvantage of long-term, environmental goals. Neither do es this project have impacts, which are individually limited, but cumulatively consi derable. This project will have no potential

environmental effects that will cause subst antial adverse effects on human beings, either directly or indirectly.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 187 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 Based upon consideration of the informa tion provided in the comments to the Environmental Checklist and other analyses perfo rmed for this project, it does not have the potential to degrade the qualit y of the environment or to interfere with either shortterm or long-term environmental goals. T here will not be any significant cumulative impacts. Finally, the project will not cause any direct or indirect substantial adverse effects on human beings.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix G: Environmental Impact Analysis for Rule 4570 June 15, 2006

C - 188 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix H: Recent Dairy Emission Research June 15, 2006

C - 189 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

# APPENDIX H

RECENT DAIRY EMISSIONS RESEARCH FOR PROPOSED RULE 4570 (CONFI NED ANIMAL FACILITIES)

June 15, 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix H: Recent Dairy Emission Research June 15, 2006

C - 190 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

### RECENT DAIRY EMISSION RESEARCH

I. Latest Research Supports Comprehe nsive Strategies for Dairy Emissions

Reductions

New research studies carried out under the direct ion of California air quality regulators

have confirmed that dairies are complex sources of air emissions. This research demonstrates significant, landmark progress in both understanding t he basic nature of dairy emissions and in controlling those emissions.

The studies also provide new information useful for designing effective control strategies to reduce dairy emissions. Current regulatory efforts are consistent with the

current science and will ensure reduced emissions and cleaner air, while minimizing unnecessary economic impact to stat e, regional and local economies.

The California Air Resources Board, the San Joaquin Valley Air Pollution Control District, and the dairy industry’s environmental coalition, CARES, collaborated on three projects that have improved the understanding of both the nat ure of the dairy emissions

themselves and the most effective ways to reduce those emissions:

• A study at UC Davis, led by Dr. Fr ank Mitloehner, which focused on emissions

from cows housed in environmental cham bers to evaluate emissions directly from cows and their fresh manure;

• A study at two operating dairies in t he San Joaquin Valley, led by Dr. Chuck Schmidt, in which measurements were made at many locations on and around the dairy facilities including the co rrals and turnouts, bedding areas, lagoons, feed storage areas, flush lanes, and bunker feed; and

• A study by Dr. Schmidt to validate t he effectiveness and capture efficiency of using flux chambers to quantify emissions.

The testing portions of these studies are now complete and detailed final reports are being prepared. When available, reports will be posted at: www.arb.ca.gov/ag/caf/caf.htm.

The studies build upon the existing body of research. The new studies put California solidly at the forefront of dairy emissions research. They have produced significant findings that underscore the importance of science-based regulations and addressing the complexity of dairy emissions. Perhaps the most important finding of all is that dairy emissions are extraordinarily complex, vary ing not only season to season, but from dairy to dairy, and from place to place within a dairy. Emissions can vary substantially depending on weather, types of feed, and management styles and many other factors. ARB sponsored research is underway with the goal of modeling emission at individual dairies based on site-specific characteri stics. Other key findings include:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix H: Recent Dairy Emission Research June 15, 2006

C - 191 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 • Cattle feed stored on California dairies ma y be a larger source of ozone-forming

emissions than the cows or their manure;

• Emissions of ethanol and methanol from cows and their fresh manure appear to be the dominant variety of VOCs emitted, and ar e more significant than previously thought;

• Manure in drylot corrals appears to be an important source of VOC and ammonia emissions on some dairies;

• Manure storage ponds, also known as lagoons, once suspected as a major source of airy emissions, appear to emit a comparatively small share of overall dairy emissions;

• Emissions of a class of VOC compounds know n as volatile fatty acids (VFAs) are not as significant as previously thought;

• Emissions can vary considerably from dairy-to-dairy and seasonally.

California regulators and the dairy industr y have already taken significant steps to reduce overall dairy emissions:

• In the San Joaquin Valley, where more than 80 percent of the state’s dairy industry is located, all new or expandi ng dairy operations have been required since 2004 to adopt stringent emissions r eductions measures (known as Best Available Control Technology or BACT) before receiving a construction permit.

• Existing dairies in the San Joaquin Valle y dairies are required to adopt measures

known as Best Available Retrofit C ontrol Technology (BARCT); these will be covered under new regulations co llectively known as Rule 4570.

Both actions are required under Senate Bill 7 00 (Florez), a new state law that mandates air pollution permits for large farms and livesto ck facilities. For existing dairies in the San Joaquin Valley, proposed Rule 4570 would require dairy operators to adopt at least 19 separate management practi ces aimed at reducing emissions – and is expected to reduce overall dairy emissions in the San Joaquin Valley by about 25 percent. Information regarding this rulemaking is available here: www.valleyair.org/Workshops/public_workshops_past.htm#Rule%204570.

While the studies by Dr. Schmidt and Dr . Mitloehner have provided valuable new information, they do not fully address air emi ssions from dairies. Additional work is needed to allow a comprehensive update to the in terim emission factors currently being used for dairies. To this end, longer-term research is bei ng undertaken. At the January hearing of the Air Resources Board, the Board approved a proj ect with UC Davis to begin development of a proce ss-based dairy emissions model, which is designed to

model emissions at individual dairies and to further improve understanding of biological processes that result in dairy emissions. Additional research focusing on appropriate methods for storing and managing feed, bes t management practices for corrals, and

other innovative control methods is also already under way at California State University, Fresno. Future studies may also be necessary, such as investigations ofSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP June 18, 2009

Appendix H: Recent Dairy Emission Research June 15, 2006

C - 192 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 emissions from land application of manure, solid manure handling and other areas of

dairies.

Later in 2006, there are tentat ive plans to hold a research symposium to discuss recent dairy research, ongoing effo rts, and future plans.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP May 15, 2009

Appendix I: Draft Alternative Mi tigation Measure Policy June 15, 2006

C - 193 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 

# APPENDIX I

ALTERNATIVE MITIGATION MEASURE DESCRIPTION PROPOSED RULE 4570 (CONFI NED ANIMAL FACILITIES)

June 15, 2006SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: 2006 Final Staff Repor t submitted with SIP May 15, 2009

Appendix I: Draft Alternative Mi tigation Measure Policy June 15, 2006

C - 194 Final Staff Report with Appendices For Proposed Re-Adoption of Rule 4570 ALTERNATE Mitigation Measures Under Rule 4570

“a mitigation measure that is determi ned by the APCO, ARB, and EPA to achieve reductions that are equal to or exceed the reductions that would be achieved by other mitigation measures listed in this rule t hat owners/operators coul d choose to comply with rule requirements."

• Alternate mitigation measures provide a great opportunity to take advantage of new technologies and ideas.

• Will allow us to advance air pollution cont rol at confined animal facilities as more is learned about emissions and processes.

• To make this provision work – we must assure and document that every new alternate mitigation is as effe ctive as other rule options.

• Purpose of policy is to ensure that each proposed alternate technology is fully

evaluated and that evaluatio n is fully documented.

• Policy is consistent with ex isting ATC application process.

• Substitute measures cannot be implemented until fully approved.

• Applicants are required to submit specif ic detailed information in writing.

• Policy includes a detailed evaluation pr ocedure to be performed by District air quality engineers.

• Alternate technologies must be shown to be equally or more effective or they will not be approved.

• Includes Monitoring and Recordkeeping requirements to assure that proposed

measures are enforceable.

• Policy provides for full ARB and EPA re view as required by the rule. Any

comments must be addressed to EPA and ARB satisfaction.