SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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APPENDIX C 

2006 FINAL STAFF REPORT SUBMITTED WITH FOR 

RULE 4570 (CONFINED ANIMAL FACILITIES) 

June 18, 2009 
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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, Senior 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 Air Resources Board (ARB) and 

United States Environmental Protection Agency (EPA) classified the San Joaquin Valley 

Air Basin (SJVAB) as a non-attainment area for 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 anticipated 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 the District’s Ozone Plan, it is subject to 

Federal Register, Clean Air Act (CAA), and California Health and Safety Code (CH&SC) 

requirements. Additionally, anti-backsliding provisions commit 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. 
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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 adoption 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 at 

least 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. 
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Proposed Rule 4570 is also intended to fulfill the following CH&SC requirements 

created by the passage of California’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) 
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B. Scope of Proposed Rule 4570 

Rule 4570 is properly limited to VOC regulation. 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 ozone 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 information. Due to the fact that the 

aforementioned sections only apply to ozone and ozone precursors, controlling 

emissions of other non-ozone related pollutants, such as ammonia, is not mandated or 

permitted. 

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

emissions from CAFs and determined that the rule should focus on the control of 

volatile organic compounds (“VOCs”) as ozone precursors. 

Ammonia is not being targeted by this rule because ammonia is a particulate matter 

precursor and not an ozone precursor. Some commenters inaccurately stated that 

Proposed Rule 4570 must regulate ammonia 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 2004. 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 because, based on the District's PM-10 Plan; 

the preliminary results from the California Regional PM10/PM2.5 Air Quality Study 

(CRPAQS); and the Ninth Circuit decision in Association of Irritated Residents vs. U.S. 

Environmental Protection Agency, 423 F.3d 989 (9th Circuit 2005), reducing ammonia is 

not an effective method of achieving attainment for particulate matter. Oxides of 

nitrogen (NOx), not ammonia, are the limiting reagents in the formation of PM in the San 

Joaquin Valley. The District could reduce over half of the ammonia from CAFs and not 

affect particulate matter formation. Furthermore, CH&SC 40724(a) requires the District 

to regulate PM precursors "in a manner commensurate to other source 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 because 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 Valley was not designated as nonattainment 
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for PM2.5 until April 5, 2005, well after the January 2004 applicability date. Thus, 

CH&SC 40724(a) does not require regulation of PM2.5 precursors in the San Joaquin 

Valley. 

Returning to the rule at issue here, Proposed Rule 4570, even if the District agreed that 

CH&SC 40724.6 applied to all "air contaminants" 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 must have some relationship to the pollution 

problem being addressed. Since Proposed Rule 4570 seeks to reduce ozone pollution, 

it would be nonsensical to attempt to control ammonia, soot, odor, or other "air 

contaminants" that have no effect on ozone levels in the San Joaquin Valley. Such a 

regulation would not survive the required socioeconomic analysis because the money 

spent on controls would not result in an improvement in ozone levels in the San Joaquin 

Valley. Therefore, such controls would not be considered "feasible." 

In addition, the District is prohibited from requiring controls in Proposed Rule 4570 that 

would duplicate controls required for particulate 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 4550 (Conservation Management Practices) 

was adopted pursuant to CH&SC 40724. Rule 4550 contains the required PM controls 

for agricultural sources, including confined animal facilities. As a result, the present 

ozone rule, Proposed Rule 4570, could not similarly 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 section and assess, amongst other things, "the 

nature and quantity of emissions 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 controlling 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, this 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 not require NOx controls at 

CAFs. This is because animals and manure emit minimal quantities 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 Rules 
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including, but not limited to, District Rules 4301, 4304 through 4308, and 4701 through 

4703. 

Accordingly, because Rule 4570 as a measure for the District’s Ozone Plan pursuant 

the authority set forth in H&SC section 40724.6, which authorizes the regulation of 

ozone and ozone precursors, this rule focuses on the regulation of VOCs, which are the 

pollutants that contribute to the District’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 pollution 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 structure, building, installation, barn, corral, 

coop, feed storage area, milking parlor, or system for the collection, storage, treatment, 

and distribution of liquid and solid manure, if domesticated animals are corralled, 

penned, or otherwise caused to remain in restricted areas for commercial 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, including, but not limited to, emission factors for 

confined animal facilities; the effect of those 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 following 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/lcaf05/lcaf05.htm accessed 2/24/06 

D. Permits Requirements 

CH&SC 40724.6(c) provides the District with the authority to require permits on facilities 

with less than one half of any applicable emissions threshold, if they make certain 

findings, as quoted below: 
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"A district may require a permit for a large confined animal facility with actual 

emissions that are less than one-half of any applicable emissions threshold for a 

major source in the district for any air contaminant, including, but not limited to, 

fugitive emissions in a manner similar to other source categories if, prior to imposing 

that requirement, the district makes both of the following 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 violation of a state or 

federal ambient air quality standard and 

(2) The requirement for a source 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, determining 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 sources. 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 (RACT) is required by CAA 182(b)(2) and 

182(f) for any facility with at least ten (10) tons per year (tpy) of VOC emissions. The 

emissions factors for confined animal facilities 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 rule cannot be postponed until 

finalization of the emission factor due to the CH&SC 40724.6 requirements for rule 

adoption by July 1, 2006. Preliminary discussion with EPA staff suggest that, due to the 

current uncertainty of the emission factors, at this time EPA will consider the RACT and 

large CAF thresholds to be equivalent. Therefore, staff will address those facilities 

defined as "large CAF" by the ARB in Proposed Rule 4570 to be adopted on or before 

July 1, 2006. Later, after emission factors are more refined, staff may amend this rule 

to address CAFs below the large CAF definition, but at or above 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 understanding its impact on air pollution is not as 

well established compared to other traditional stationary sources under the jurisdiction 
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of the District. New scientific findings characterizing and quantifying dairy, poultry, and 

other animal emissions and possible control 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. Frank Mitloehner, which focused on emissions 

from cows housed in environmental chambers to evaluate the emissions 

produced directly from cows and their fresh manure. 

• A study at two operating dairies in the 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 the effectiveness and capture efficiency of 

using flux chambers that were used to quantify emissions in the dairy studies. 

These studies have provided significant findings 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 preliminary research data, staff will propose rule 

adoption no later than July 1, 2006. 

Since control efficiencies for technologies and emission factors may change based on 

new research, staff structured the rule such that facilities may comply with rule 

requirements utilizing management practices and machinery that owners/operators 

already have access to onsite. This is intended to implement BARCT, while preventing 

owners/operators from being 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 capital investment beyond the mitigation measures currently 

being proposed in Rule 4570. At that time, the emissions 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, staff left the testing requirements flexible to 

prevent owners/operators from being required to invest significant capital in testing that 

is later found to be ineffective or not the most cost effective method. Furthermore, the 

rule provides the flexibility for the APCO, ARB, and EPA to add additional test method 

options that they believe are appropriate. This concept acknowledges that, as research 

continues, new, more effective, and less expensive 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 emissions from CAF. Additional work is 

needed to allow a comprehensive update to the emission factors currently being used 

for CAF. As additional research, such as that being undertaken by the California Air 
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Resources Board, becomes finalized, this rule 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 including, 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 restricted areas for commercial agricultural 

purposes and fed by a means other than grazing. (CH&SC 39011.5 (a)(1)) 

Due to the different methods of confinement and associated manure management, 

there is no typical CAF. The design and operation of a CAF varies depending on animal 

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

owners/operators. This is why Proposed Rule 4570 provides a menu of options for the 

owners/operators. This acknowledges that not all facilities 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, the 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 ranches for egg production or as broiler ranches 

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

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

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

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

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

approximately 10,000 birds at any one time. 

This typical practice of having no more than 650,000 birds on a single property or 

contiguous properties is for biosecurity purposes. Although the farms that make up a 

ranch may be operated as a single facility all using the same equipment, personnel, and 

operators and having a single owner, if the farms are not on contiguous properties they 

will each be considered a separate agricultural source based on the definition of a 

single agricultural source in CH&SC Sections 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, approximately 61% of the chicken layer houses and a majority of 

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

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

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

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

for ventilation, particularly during colder weather. 
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Studies indicate that most chicken layer houses produce approximately two cubic yards 

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

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

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

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

positioned above the ground. On average, every 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 floor of the layer houses. However, many 

facilities list less frequent waste removal, ranging from one (1) to three (3) times per 

year (every 17-52 weeks) as a control technique used to comply with District Rule 4550 

Conservation Management Plan (CMP). Several mitigation measures in Proposed Rule 

4570 and Rule 4550 that the owners/operators could choose do not affect waste 

removal frequency. Therefore, owners/operators can comply with both Rule 4550 and 

4570. 

In broiler facilities, complete litter removal from the house 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 every 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 ambient 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 grown 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 live bird weight. On average, for each 

pound of live weight gained, meat birds produced 0.52 pounds 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 either swept or scraped from the 

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

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

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

later in this report. However, less than 15% of the poultry operations in the San Joaquin 

Valley use liquid manure 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 the animals and decreases productivity, many 

facilities implement controls for ammonia. The humidity, litter additive, moisture, and 

ventilation controls widely used to control ammonia also constitute BARCT for VOC 

emissions. Based on industry comments, staff believes that the majority of poultry 

facilities in the SJVAB already implement BARCT for VOC emissions. Furthermore, the 
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studies conducted to determine emissions factors for poultry were on poultry houses 

that had implemented BARCT, thus the baseline for poultry emissions includes BARCT. 

 

B. Dairy Operations 

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

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

and give birth. Typically, the gestation period for dairy cattle is nine (9) months and 

dairy cows are bred again approximately four (4) months after calving. Milk production 

typically peaks shortly after calving and then declines. Commonly 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, calves, and bulls (for breeding purposes). 

Approximately 25% of a milking herd is replaced each year, but replacement levels can 

be as high as 40% for intensively managed herds (EPA 2001). 

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

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

aforementioned. The freestall barn is the 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 stalls for resting. Standard freestall barns 

have a feed alley in the center 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 confined in or have access to 

drylots. Drylots are typically fenced in areas 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 facilities. In this type of housing system, 

cows are confined in a stall for feeding, but have access to a dry lot or pasture for 

exercise. A mechanically or manually cleaned gutter is located behind each row of 

stalls for manure collection and removal. 

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

nursed for four (4) to five (5) days after birth. Calves are then fed a milk replacement 

until weaning, which generally occurs at about eight (8) weeks of age. During this 

period, a feed grain based starter diet is introduced. This starter diet is fed to calves 

until they are approximately three (3) months old. At approximately three (3) months, 

calf rumen development allows a shift to a roughage-based diet. 

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

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

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

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

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

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

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

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

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

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

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

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

and dried for disposal through land application. 

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 operations in the beef 

industry: cow-calf operations, backgrounding operations, and finishing operations. 

These operations are typically conducted at separate locations that specialize in each 

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

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

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

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

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

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

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

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

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

to180 days, animals in finishing operations will reach slaughter weights of 1,050 to 

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

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

typically have between 1.5 to 3.5 cattle turnovers per year. 

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

truck access. The animals are typically fed two (2) to three (3) times per day using feed 

bunks located along feed alleys that separate the individual pens. 

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

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

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

be cleaned during the finisher cycle. However, there is significant concern and risks 

associated with entering areas where beef cattle are housed. 
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For Proposed Re-Adoption of Rule 4570

D. General Description for Swine Operations 

The production cycle for hogs has three (3) phases: farrowing, nursing, and finishing. 

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

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

nursed for a period of three (3) to four (4) weeks until they reach a weight of 

approximately ten (10) to fifteen (15) pounds. Typically, there 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 ration until they reach a weight of approximately fifty (50) 

to sixty (60) pounds. At this point, they are typically eight (8) to ten (10) weeks of age. 

Then the animals are fed a growing and finally a finishing ration until they are 

approximately 240 to 280 pounds at which point they are approximately 26 weeks of 

age and ready for slaughter. The diet varies, but it typically includes small grains such 

as wheat and barley, corn and soybean meal. 

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

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

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

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

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

through slats in the floor to a pit underneath the floor. 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 with 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 nitrogen requirements due to concern about 

the impact of excess nitrogen on surface and ground 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 Quality 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 rectangular box that is either tractor drawn or 

truck mounted with a spreading device at the rear end. During spreading, the manure 

moves to the rear of the box by either a belt 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 tractor drawn or truck mounted tank known as a 

liquid manure spreader. The manure may be forced out of the tank under pressure 
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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 incorporated through the use of a manure 

injection device, typically attached to a tractor; 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 absorbed into the soil and apply any solid manure only 

after it has been treated with an anaerobic digestion process, treated with an aerobic 

digestion process, or dried to a moisture content of less 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. Similarly, 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 sources of VOC on CAF may include: enteric 

(i.e. eructation and respiration), bedding, excreta, and feed. (Schmidt, 2004) In 

excreta, the majority of the non-methane volatile organic compounds (NMVOC) 

originate from the decomposition of undigested protein (Hobbs 2004). Sources of VOC 

from excreta include animal housing, yards, manure storage areas, land spreading, 

solid separator piles, and lagoons. 

The District extensively reviewed current research 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, including feed storage, land application, and 

composting; 
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For Proposed Re-Adoption of Rule 4570

• Category 3- VOC from Miscellaneous Dairy Processes: Several VOC including 

methanol were not measured and several important processes including feed 

storage, land application, and composting were not included; 

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

aromatics and ethanol were not measured; 

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

several VFA calculations so it may underestimate the VFAs at dairies; 

• Category 6- Phenols from Dairy Processes: Not included because no information 

regarding the relationship between phenol formation and diet and process 

conditions was provided to the APCO; and 

• Category 7- Land Application, Feed Storage, Settling 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 Systems (if applicable), and

• Solid Waste Handling Systems (if applicable).

Not every facility has all of the above emission 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 factors. The emission reduction calculations are performed 

using the most recent emission factors accepted 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 including an elephant, a horse, seven (7) 

Holsteins, four (4) Jerseys, and a Hereford cow. This study and the subsequent 
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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 species. 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 complete. Staff was unable to locate 

comparable emission factor data that addressed all emission sources on these 

facilities. Therefore, the Ritzman study and Ritzman-based 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 those currently used by the District's Permit 

Services for permitting purposes. Those factors are based on the 2005 

California Department of Food and Agriculture and Foster Farms source test of a 

chicken broiler facility; information from the Dairy Permitting Advisory Group 

(DPAG) (see www.valleyair.org/busind/pto/dpag/dpag_idx.htm for details); and 

ASAE manure production equivalents. 

Table 4 details the emission factors, based on these sources, which will be used for 

calculation purposes. As noted previously, the emission factors may be revised in the 

permitting process to reflect the latest approved research information. 

Table 4: Emission Factors (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 varies 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 the 
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For Proposed Re-Adoption of Rule 4570

Total VOC Emitted 

by CAFs (lb/yr)

Total VOC Emitted by

CAFs (tons/day)

Total VOC Emitted 

by Large CAFs (lb/yr)

Total VOC Emitted by 

Large CAFs (tons/day)

Milk Cows 37,432,525 51.28 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 because it is the weighted average of the 

number of animals in facilities with freestalls (71%) and the number of animals in 

facilities without freestalls (29%). Specifically, the calculation is: 21.7 x 71% + 19.3 x 

29% = weighted emission factor = 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; Table 5 summarizes the results. 

Dairy

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

“California Agricultural 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 and 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 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. 
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C - 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/yr)

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 submitted to the District. Based on those applications the 

following ratios, listed in Table 7, were developed. 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 needs 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= 202,667 dry cows 

1,266,666 x 0.11 = 139,333 calves 

Now we can use the ratios in Table 7 to estimate 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 the 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. 
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C - 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/yr)

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/yr)

Layers 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 

Turkeys 8,071,297 0.100 807,130 4,728,720 0.100 472,872 

Total 2,583,221 67,397,155 41,533,809 1,574,625 

 Table 10: Total 2005 Poultry Animals

Beef and Other Cattle

The following table includes other cattle facilities in the San Joaquin Valley, from a 

USDA California Agricultural Statistics 2004 Report and beef on feedlots from the 

California Farm Bureau Federation. Staff 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 this 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 therefore, averaged the emission factors for heifers 

and calves in order to obtain the emission factor for other cattle. This was used to 

develop Table 9. 

 

Poultry and Other Animals

Staff obtained an estimate of the number of layers in the SJVAB from the USDA census 

data. Since the ARB Proposed Emission Methodology assumed 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 Consider the Adoption of a 

Regulation Establishing a Definition 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. 
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C - 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 0.190 742 - 3,903 0.190 - 

Goats 0.960 32,794 - 34,160 0.960 - 

Sheep 0.960 262,848 - 273,800 0.960 - 

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

Total 1,025,649 470,399 90,000 414,000 

 Table 11: Total 2005 Other Animals

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-cattle, staff assumed that the non-cattle 

population has been relatively constant since 2002. Based on the District's permit 

database, staff found that approximately 90,000 swine are 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 facilities 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 Board, over 157,400 tons of manure was shipped from the 

Chino Basin to the SJVAB. Many of the 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. Therefore, staff does not believe the SCAQMD 

dairy operations are comparable to the SJVAB dairy operations. 

In terms of size of facilities, a significant number of CAFs would be below the proposed 

Rule 4570 applicability thresholds. Information 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 significant number of CAF already utilize enough 

mitigation options listed in the rule to comply with the rule requirements. 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 total number of swine in each county, staff estimated the number of 

swine facilities that would be affected. This is summarized in Table 12. 
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For Proposed Re-Adoption of Rule 4570

Table 12 

Estimated Number of Facilities 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 increased over 30% from 1997 to 2002. Local 

county agricultural reports show that the inventory of milk cows increased 2 to 4% 

between 2002 and 2003. In contrast, USDA census data indicate relatively stable or 

decreasing populations of beef cattle, hog, layer and broiler chicken, turkey, ducks, and 

geese from 1997 to 2002. Based on CEQA projects 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 were completed. Although it should be noted that some of 

the CEQA projects may not be completed. Therefore, staff assumed a conservative 

4.5% growth for the dairy industry based on historical data from CDFA. 

III. EMISSION CONTROL TECHNOLOGY 

This section summarizes the requirements for control and the possible control 

techniques for reducing air emissions from CAFs. The information assembled was 

obtained through a review of available literature and research. The goal of the literature 

review was to identify possible controls. Some of these controls do not appear in the 

rule as mitigation measures or on any list due to a lack of scientific data regarding VOC 

reductions. However, they are identified in this report to provide owners/operators with 

ideas of some mitigation measures that have been proposed as potential mitigation 

measures and, with further information, may be approved as alternative mitigation 

measures. 
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C - 24 Final Staff Report with Appendices 

For Proposed Re-Adoption of Rule 4570

A. Technology Requirements 

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

With the changes to the CH&SC and the resulting loss of exemption 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 process 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 undergoing modification with emission 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 permitting requirements and that emit or may emit 

one or more affected pollutant, either as a “major” source subject 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 defined by the ARB, and CAFs with emissions 

that reach or exceed 50% of the major source threshold were required to obtain permits. 

The existing sources that apply and receive permits are not reviewed as “new” sources, 

but rather as sources with a “loss of exemption.” This means that BACT is not required, 

but the source may be subject to emission reduction requirements under other local 

prohibitory rules, which are local rules other than permitting 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 mitigation plans. The level of mitigation 

required by the CH&SC is BARCT. This term characterizes a standard of emissions 

control for existing, traditional sources. Under federal air pollution programs for 

traditional sources, different levels of control are expected of new sources (best 

available) and existing sources (reasonably available), with the understanding that there 

are more options available at a more reasonable 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 pollution problems may demand more 

effective pollution control than what is usually considered “reasonably available.” Local 

air districts have adopted many rules to implement 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 emissions. BACT is utilized in the 
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C - 25 Final Staff Report with Appendices 

For Proposed Re-Adoption of Rule 4570

permitting process on a case-by-case basis. BARCT 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 reduce 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 dietary 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 VOC emissions from cow flatulence (enteric) 

and manure, while ensuring that animal health is not jeopardized. 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 Goats: Angora, Dairy, and Meat Goats in Temperate & 

Tropical Countries, 1991; 

• Nutrient Requirements of Horses, 1989;

• Nutrient Requirements of Poultry, 1994;

• Nutrient Requirements of Rabbits, 1977;

• Nutrient Requirements 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 Science: Animal and Waste 

Management Jan. 2005 S.L. Archibeque et al presented a presentation titled "Feeding 

High Moisture Corn Instead of Dry Rolled Corn Reduces Odor Production in Finishing 

Beef Cattle Manure Without Sacrificing Performance". 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. Additionally, in the Journal of Dairy Science 

87:2546-2553 article "The Effect of Steam Flaked or Dry Ground Corn and 

Supplemental Phytic Acid on Nitrogen Partitioning in Lactating Cows and Ammonia 
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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 Schmidt at dairies within the SJVAB suggested 

significant emissions from feed in the feed lane. Therefore, regular cleaning of feed 

from all areas of the facility are considered control measures. This is because by 

limiting the quantity of time that the feed is onsite, one limits the quantity of time that the 

feed may emit VOC. Additionally, it minimizes the amount of moisture that comes in 

contact with the feed. Since the microorganisms that breakdown feed in a manner that 

releases VOC require moisture, by minimizing the moisture one can minimize the 

microorganism's activity and thus VOC emissions. 

Weatherproof Storage and Covers 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 for covering silage and grain. These include, 

but are not limited to, silos, tarps, and bags. There are several benefits of utilizing bags 

to store silage. Because of the low storage height, there is less danger of falls from 

elevations. Additionally, there is reduced spoiling of silage. However, some of the 

disadvantages include added cost of approximately $10 per ton of silage based on 

information found at the following website: 

http://bse.wisc.edu/hfht/tipsheets_html/silagebag.htm accessed 2/16/06. Covering 

silage and venting it to a VOC control device is considered beyond BARCT because it 

has not been achieved in practice at facilities 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 capital 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 anaerobic 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 process 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 implement. This is primarily due to the Regional Water Quality 

Board requirements for land application of animal waste in a manner that minimizes or 
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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 believes 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 denitrification 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 containing probiotic reduced VOC emissions from the broiler 

house. The District's most recent BACT analysis for broiler facilities noted that feeding 

the poultry lactobacilli containing probiotics likely reduces VOC emissions from poultry. 

Addition of enzymes, such as those from yucca and soybeans also may reduce VOC 

emissions by increasing the animal’s absorption or digestion of nutrients thereby 

reducing the quantity of protein and volatile fatty acids excreted in the manure and litter. 

Information notes that poultry feed additives may be used to reduce the feed 

decomposition or oxidation in poultry feed, thus rate of VOC emissions. 

Feed additives that improve digestion efficiency 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 demonstrated 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 quantity of cellulose (Sutton 1998). The study 

also noted reduction in VOC emissions with the addition of 10-ppm anthraquinone, and 

use of reduced protein diets with supplemented amino acids. In swine, the Journal of 

Animal Science 2003 Volume 81:1754-1763 article "Ammonia, volatile fatty acids, 

phenolics, and odor offensiveness in manure from growing pigs fed diets reduced in 

protein by Otto et. al; Purdue 1998 Swine Day Report titled "Addition of Carbohydrates 

to Low Crude Protein Pig Diets to Reduce Manure Nitrogen Excretion and Odors" by 

Sutton et al; and Purdue 2000 Swine Day Report titled "Reduction of Odorous Sulfide 

and Phenolic Compounds in Pig 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 supplemented 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. 
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Since swine and chickens have a different digestive system and nutrient requirements 

from cattle, poultry and other animals, staff was unable to determine whether or not 

these feeding strategies would reduce VOC emissions from other 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 utilize these options for their 

operation if they satisfy the requirements for 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. 
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insufficient data for staff to determine that the measures would result in volatile organic 

compound (VOC) emission reductions and not cause harm to animals. Stakeholders 

may utilize these methods to comply with rule requirements if they could demonstrate, 

to the satisfaction of the ARB, APCO, 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 the owner/operator could have chosen. 

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

removed from the list because staff was 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 other than corn, instead 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 supplemented 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 anthraquinone to animals other than swine; 

11. Feeding feed additives that reduce feed 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 (also 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 containing supplemental fats. 
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C. Housing/Animal Waste Mitigation Measures 

Rapid Drying, Rapid Removal of Manure, and Moisture Minimization

In housing (including freestalls, pens, corrals, milk parlors, etc) moist conditions lead to 

anaerobic decomposition of manure. Suppression of emissions of reduced gaseous 

compounds can be achieved by faster drying of animal waste, minimization of moisture, 

and increased removal frequency. Increased removal frequency reduces anaerobic 

decomposition by reducing the amount of manure not exposed to the surface and 

oxygen; minimizing the moisture in the manure and feed thus minimizes the moisture 

needed by the microbes that decompose 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 the 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 facilities 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 the waste and employing moisture minimization 

processes minimize the activity of these microbes. Several studies have found that 

volatile fatty acid emissions from manure increase with moisture. Koziel et al stated in 

their paper, “Measurements of Volatile Fatty Acids Flux from Cattle Pens in Texas, 

"[m]easured flux was proportional 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. Therefore, 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, animal urination, and 

animal respiration. By using non-manure based bedding you are minimizing the amount 

of manure products present in the housing that have the potential 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 stockpiles, which emit VOC, 
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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 animal 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 wall material, have been used for enclosures 

vented to biofilters. Since all the animal 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, dietary manipulation, animal waste removal 

frequency, and animal waste additives may not be necessary to ensure VOC 

reductions. It may allow owner/operator more flexibility in managing their animals and 

their manure/litter. It may also result in fewer monitoring, recording, and testing 

requirements, since management practices inside the building may not be regulated. 

This option alone may achieve highest VOC reductions 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. Depending 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 than it would be in a free stall or other housing with minimal or 

no mechanical ventilation. Dr. Terry Smith 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 increase 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, already typically house animals in enclosures 

with mechanical ventilation. Therefore, to utilize this control, such facilities would only 

need to install a VOC control system and increase ventilation rates. Nicolai Pork in 

Hector, Minnesota; University of Minnesota 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 options). SRC in Urbana-Champaign, Illinois 

vent their swine-finishing house to a wet scrubber to reduce dust and VOC. 

The University of Minnesota Extension publication number BAEU-18 dated March 2004 

provides guidance for ventilation rates for dairy cows, chickens, turkeys, and swine 

housed in buildings. Additionally, it provides guidance for venting the building to a 

biofilter and configuring the biofilter. Cornell University Dairy Facilities Engineering 
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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 BARCT due to the high cost and the fact 

that it has not been achieve in practices at facilities similar in size to those defined as 

large CAFs by the ARB. 

Thymol

Thymol is plant oil derived from 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, these results were from studies conducted for 

short period (less than a month) therefore additional data is required to determine the 

long-term effects of these oils. 

Due to the fact it has not been used at facilities 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 minimize moisture. However, 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 minimizing 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 animal movement, thus the surface area over 

which manure is excreted and VOC emitted. However, this option is extremely costly, 

thus considered beyond BARCT. 
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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 the measures would result in volatile organic 

compound (VOC) emission reductions and not cause 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, 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 the 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 Manure Piles During the Wet Season

As noted above, wet manure promotes anaerobic decomposition, which emits significant 

VOC. Therefore, practices, such as covering piles that minimize exposure to moisture 

also minimize VOC emissions. 

 

Compost

Current research suggests that aerated static piles (ASPs), in-vessel technology, and 

within vessel technology (i.e. Ag Bag) with the captured air vented to a secondary 

control may reduce VOC emissions from the pile by 23-95%. Preliminary data from 

Schmidt/Card's 2004 ARB Research Symposium presentation suggests that solid 

storage may account for approximately 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 aeration- 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 blower that forces air through the pile. 

Both in-vessel and within vessel systems enclose the compost mix in a bag, vessel, or 

structure and mechanically aerates the mixture. In all the systems, the captured air is 
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vented to a secondary control device, a device to further reduce VOC emissions, such 

as a biofilter. 

It should be noted that the California Integrated Waste Management Board regulations, 

including but not limited to California Code of Regulations (CCR) Title 14, Division 7, 

Chapter 3.1, Articles 1-4, may limit the materials that may 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 away 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 preliminary 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. However, these are extremely 

costly and producers note that they require significant 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 determine that the measures would result in volatile organic 

compound (VOC) emission reductions and not cause 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, 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 the owner/operator could have chosen. 

1. Thermal Conversion (Including Combustion and Gasification 

 Technologies that burn waste 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), pyrolysis (thermal treatment in the absence of 

air, resulting in the production of pyrolysis 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 conversion technologies are not suitable for raw 

dairy manure due to the high-energy costs to dry the manure to an acceptable 

moisture level. Additionally thermal conversion has the potential to create air 
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emissions, although there are methods of controlling these air emissions. The 

University of Southern Illinois is testing this potential control option. 

2. Windrow Composting with Management Practices 

 Some stakeholders have suggesting management practices such as controlling 

the moisture content, carbon to nitrogen content, 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 information specifying the appropriate parameters 

for these measures and demonstrating that these measures would result in VOC 

emission reductions 

E. Solid Separators 

Solid separators may be used to reduce loading 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 solid separation can occur at any point during manure 

handling and treatment processes, the separation methods used closest to the point of 

origin (source separation systems) are significantly different than the methods used 

after the manure has been diluted 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 flow 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 belt and into a separation collection area. 

Belt systems have been used in poultry operations 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 delayed separation, separation after the urine 

and fecal matter have been mixed or diluted with flush water. Gravity, mechanical, and 

chemical are the main types of solid separation. 

Gravity separation, also called passive separation, uses the natural downward force of 

gravity to separate the liquid from the solids. Solids denser than the liquid settle to the 

bottom and solids lighter than the liquid form a crust on the top. Liquid is removed by 

pipes between these two regions or by overflow 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 settling 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 initial quantity of solids in the waste and the retention time. 
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An alternative to gravity separation is mechanical separation. This relies on a 

combination of moving parts and gravity to separate manure solids from the waste 

stream, mostly utilizing the size of the solid particles to achieve separation. While 

mechanical processes can achieve separation faster than gravity processes, there are 

tradeoffs, for example, the expense of the power to drive the machinery and the 

maintenance required of moving gears. 

Mechanical systems include sloping stationary screens, vibrating screens, screw 

presses, drag chain separators, roller presses, and centrifuges. A sloping stationary 

screen is the most common method of mechanical solid separation. The slurry is 

deposited at the top edge of the sloping fabric screen where the screen is virtually 

vertical. As the slurry moves down the slope, 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 press, 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 efficiency of solid separation. Another system 

is the drag chain system. The slurry is applied to a perforated screen. Free liquid flows 

through the perforations and into a collection basin. Chains equipped with paddles pass 

over the surface of the screen. Variations in solid content affect the efficiency of this 

method. The roller press system consists of a roller press containing a rotating 

perforated drum and one or more rollers. First, the slurry enters the drum where free 

liquids pass through the perforations, and the slurry moves to the end of the drum. As 

the slurry moves under the rollers, more liquid 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 the slurry, pulling the liquids to the outside 

through perforations. The solids remain on the inside wall of the perforated drum. 

There are varying opinions regarding the typical percent solid removal from different 

types of solid separators as shown in Table 13. 
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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 Separators, Robert T. Burns, 

rburns@iastate.edu. 

17%-60% University of Tenn., Performance 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 separation 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 concentration of the manure can affect the solid removal efficiency 

F. Liquid Manure Mitigation Measures 

Volatile organic compounds (VOC) are formed as intermediate metabolites in the 

degradation of organic material in manure and litter. Under aerobic conditions, any 

VOC formed are rapidly oxidized to carbon dioxide and water. Under anaerobic 

conditions, complex organic compounds are degraded microbially to volatile organic 

acids and other volatile organic compounds, which 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 nominal. However, inhibition of methane 

formation results in a buildup of VOC in the manure and ultimate volatilization to the air. 

Loading more solids in the liquid storage system than the system can handle causes 

this. VOC emissions will be minimal from a properly designed and operated 

stabilization process such as anaerobic lagoons. However, VOC emissions will be 

higher from storage tanks, ponds, overloaded anaerobic lagoons, and land application 

sites. (EPA 2001) 

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

By limiting the lagoon to wastewater not from freestall flushing, the organic loading and 

thus VOC emissions from the lagoon will be less. 

Phototrophic Lagoon

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

nmol mL-1, phototrophic lagoons, showed lower emissions of VOC than other swine 
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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 photosynthetic bloom according Do 2003. 

 

Lagoons Designed In Accordance with USDA/NRCS Recommendations

The USDA NRCS Agricultural Waste Management Field Handbook offers guidance on 

building and designing anaerobic 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 more than 11 pounds of volatile solids per 

1,000 feet3 per day entering the lagoon. If the lagoon does not have sufficient volume 

to accept all the waste sent to the lagoon and not exceed 11 pounds of volatile solids 

per 1,000 ft3 per day limit, pretreatment of liquids entering the lagoon may be used. 

This pretreatment may be solid separation. The solids separated from the liquid would 

be handled similar to other solids on the facility 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 VOC 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 waste to carbon dioxide, water, 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 promoting phototrophic conditions, however is 

considered beyond BARCT due to the fact CAFs typically do not measure these 

parameters, thus may need extensive training to understand and maintain these 

parameters. 
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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 considered beyond BARCT. 

Covered Lagoon with Gas Vented to a Control Device

Covers may be used to capture the gas produced 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 electricity. Storage covers need to be acceptable by 

local mosquito abatement district regulations. These vary from district to district, but in 

general, districts require that the cover not be liquid permeable and completely cover 

the lagoon with no gaps that would allow mosquito access to the liquid or be removable 

so that mosquito abatement personnel can treat the lagoon if needed. 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 the perimeter of the pond, pit, basin, channel, or lagoon. 

Bank-to-bank covers are continuous with the ground surface or extend only slightly 

above the ground. The design should include floatation devices to keep the cover from 

sinking into the manure. Water pumping equipment may be required to keep the cover 

free of standing water. This design can 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 inflate the cover. Pre-cast concrete posts or 

stainless steel poles may be used as supports for 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 perimeter 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 determine that the measures would result in volatile organic 

compound (VOC) emission reductions and not cause harm to animals. Stakeholders may 

utilize these methods to comply with rule requirements if they demonstrate, to the 
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satisfaction of the ARB, APCO, 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 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 potassium permanganate and hydrogen peroxide 

may be applied to the system, at the surface, 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 chemicals 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 slurry. However, ozone must be produced 

on-site, which requires costly generation and application systems. 

3. Microaerobic Biological Nutrient Management Practice 

In this system, waste products are collected and mixed with water. The mixture 

is pumped through a contact chamber and then 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 liquid then passes through anaerobic and anoxic

zones. According to technology venders, the majority of the VOC and VOC 

precursors are metabolized and incorporated into microbial biomass. Based on 

the Final Dairy Permitting Advisory Groups (DPAG) Report this has a control 

efficiency of approximately 79% for the 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 information, such as that 

specified in the Final DPAG Report, will be required to fully evaluate such a 

system. CAF owners/operators 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, manure sludge buildup, odors, preserves 

nutrients, reduces nitrates, reduces ammonia emissions, reduces flies, and many 

other things. It has been used at numerous dairy and poultry facilities, however 
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there is not sufficient data available to determine the effect of this technology on 

VOC emissions. 

5. Aquatic Cropping 

 In this option alga is grown in engineered ponds, raceways, or lagoons. Some 

suggest that the algae incorporate nitrogen, phosphorus, and VOC precursors 

into their biomass. The algae could 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 large amounts of solids are added to a liquid 

manure storage unit. Some believe that the crust serves as a biological cover 

that would reduce VOC emissions. Others believe that 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 the 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 anaerobic conditions—all of which could 

lead to increased VOC emissions. 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 bacteria. The technology introduces 

oxygen into pond systems with the 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 microorganisms rotates, much like a water wheel, 

in and out of an effluent stream thereby exposing the attached biofilm to 

alternating aerobic and anaerobic conditions. Organic compounds are oxidized. 

G. Crop Application 

Land Application

Current research suggests that the majority of emissions emitted during land application 

of manure are emitted during the first 24 hours. Therefore, rapid land incorporation, 

whenever feasible is considered a control measure. This includes rapid incorporation of 
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waste into the soil by tilling, injection, and other methods. This type control method, 

based on SCAQMD PR1127 Staff Report has a control efficiency of approximately 23%. 

Furthermore, by only applying waste with minimal biological activity, either waste that 

has already by treated or with low moisture 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 water holding capacity of the soil, and provide 

essential nutrients for plant growth. The 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 maximum limits on the quantity of manure applied 

to the land. Furthermore, the owners/operators have the opportunity to choose when to 

land apply waste, either by timing of animal 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. Therefore, tilling options may not be feasible for all facilities. 

It is further understood that these measures are not always 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 used at these times. Additionally, in wet 

weather the vehicles used to transport the 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 may 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 expected to reduce VOC emissions because the 

soil is expected to trap the 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 composting, 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 systems 
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have routinely been used in the swine industry and as well as some poultry and dairy 

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

for VOC control. 

Biofilter

A biofilter is a control technology that uses microorganisms to treat air emissions. They 

have been used at poultry, swine, and dairies (mostly in colder regions where the cows 

are housed in barns), to control air contaminants, however there may be negative 

animal health issues related to the use of biofilters. A biofilter is simply a layer of 

organic material, referred to as biofilter media, that supports a microbial population. 

Mechanical and/or natural ventilation pushes air through ducts into the air plenum; 

empty space underneath the biofilter. 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 biofilter system for a swine house. 

Figure 2 Biofilter 

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

contaminants to be treated and the concentrations, media characteristics, biofilter size 

(area) constraints, moisture control, maintenance, and cost. These parameters all play 

a role in either the efficient cleaning of airstreams or in the economic operation of the 

biofilter. The ventilation rate required is dependent on temperature and the type, size, 

and number of animals in the building. Ventilation design procedures can be found in 

the University of Minnesota Extension Publication MWPS-32, Ventilation Systems for 

Livestock House. Some building ventilation rates are shown in Table 14. 
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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 storage unit are 0.01 cfm per square foot of 

surface area. 

Media selection is another critical element because, for a biofilter to operate efficiently, 

the media must provide a suitable environment for microbial growth (including 

appropriate pH and temperature) and maintain a high porosity to allow air to flow easy. 

A proven organic media mixture for animal agriculture biofilters ranges from 

approximately 30:70 to 50:50 ratio by weight of compost and wood chips or wood 

shreds. The wood provides the porosity and structure while the compost provides 

microorganisms, nutrients, and moisture 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 increases the pressure or force needed to move 

the air through the biofilter media. This force is measured as the static pressure drop. 

A static pressure drop of over 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 critical component of a biofilter. Ducting 

must be constructed to move the air from the 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. Inadequate 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 plug some of the pore in the 

media, causing channeling and limiting oxygen flow in saturated areas of the filter, 
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thereby creating anaerobic zones in the biofilm. Recommended moisture content for 

biofilters range from 40-65% wet basis with optimum moisture content of 50% (Schmidt 

2004.) 

Finally, good weed prevention and rodent control are essential. Weed growth on the 

biofilter surface can reduce the treatment efficiency by causing air channeling and 

limiting oxygen exchange. Roots also contribute to plugging of biofilter pores inhibiting 

the flow of air through the media. Rodents, such as mice, rats, rabbits, woodchucks, 

and badgers, burrow through the warm media during the cold winter months causing 

channeling problems. Channeling, as previously mentioned, reduces the biofilter 

efficiency by providing a means of air escaping the biofilter without completely filtering 

through the media and being completely treated by the microbes. 

Gas Absorption

In a gas absorber, building air is collected and passed though an enclosed (typically 

packed) tower with the absorption media flowing counter-current to the incoming air 

stream. Gases in the air stream diffuse into and are absorbed by the media. Although 

water is used as the scrubbing media in many applications, the absorption 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 are the emissions from the generation of the electricity 

needed to convey air to the scrubber and disposal 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 building 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 scrubber 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 likely that this effluent could be land applied. 

Periodically the filter 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. 
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IV. MONITORING AND MEASUREMENT REQUIREMENTS (MMR) 

The monitoring and measurement requirements, which include minimum testing 

frequency, are designed to minimize the costs of testing for owners/operators while 

ensuring that adequate testing is conducted to demonstrate compliance with the 

appropriate mitigation measures and such measures 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 pollutants. Since the emission inventory is dependent on the 

number of animals in the SJVAB and typically 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, milkers, and dry cows) to comply with this 

monitoring requirement. The rule will not require owners/operators to maintain a set of 

records exclusively for the use of the San Joaquin Valley Air District. 

Other monitoring and testing requirements 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 currently available information, these parameters 

are not necessary to determine an emission inventory, unless the mitigation measures 

chosen are affected by these parameters. An example is monitoring feed content. 

Table 15 below lists the feed mitigation measures for dairies. 
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Table 15 

Feed Mitigation Measures for Dairies

A. Owners/operators shall incorporate at least four (4) of the following feed 

mitigation measures: 

Class One Mitigation Measures 

1. a. Feed according to National Research Council (NRC) guidelines. 

2. a. Feed animals high moisture corn 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 wet feed from feed bunks within twenty-four (24) 

hours of a rain event. 

6. a. Feed or dispose of rations within 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 mitigation 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 measures 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 testing of VOC control devices every twelve 

months to ensure that the device has not been damaged, degraded, or otherwise 

changed to the degree that it no longer achieved the desired reductions. More frequent 

testing is not required because it is a mechanical device with clearly defined operating 

parameters which are not expect to change significantly 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 effective 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, are 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 would not include control measures, such an 

increased cleaning, lagoon aerators, etc. where air is not captured by the control 

measure. 
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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. Also, 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 APCO, ARB, and EPA and may only be temporary 

until the owner/operators has demonstrated that system tested (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 socioeconomic analysis, some of these controls 

have significant costs. However, farms are eligible for numerous grants, which could 

pay for some or all of the costs of implementing mitigation measures. Some of these 

are listed below. 

A. National Programs 

Environmental Quality Incentive Program (EQIP)

This program provides financial and technical assistance to install or implement 

structural and management conservation practices. EQIP can be used for manure 

transport, composters, solid separators, land application of nutrients, and many other 

things. Approximately 60% of the total EQUIP funds are target 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 approximately 75% of the cost of the project and has 

a maximum funding per project 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.nrcs.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 approximately 50% of the cost of the project. For 

more information look for the announcement, which is usually released in early spring of 

each year, and the website at http://www.nrcs.usda.gov/programs/cig/. 
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Renewable Energy Systems and Energy 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 approximately 25% of the cost of the project. For 

more information look for the announcement or check their website at 

http://www.rurdev.usda.gov/rbs/farmbill/index.html. 

Sustainable Agriculture Research and Education Grants Program

The purpose of this program is to advance farming systems that are profitable, 

environmentally sound, and good for communities. 

For more information look for the announcement or check 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, manure 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 digesters. For more information 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 limit VOC emissions from confined animal 

facilities (CAF). Preliminary analysis of the industries indicate that the cost and 

feasibility of control options will be highly variable due to existing infrastructure and 
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current management practices at the facilities. To provide owner/operators flexibility in 

complying with the rule's control requirements, 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 combination 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 flexibility to facilities considering that CAF 

facilities vary from one another and not all controls are feasible for all facilities. 

Facilities that are unable to use the control options listed to meet the minimum 

required number of measures have the option of developing VOC mitigation 

measures that are more applicable to their facilities by demonstrating the 

efficiency of the measures. 
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 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 applicable Tables 1 through 6 of 

the rule. The mitigation measures specified 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 avenues for such approving authorities to 

accept the appropriateness of the listed measures. Owners/operators would 

demonstrate, as part of the emission mitigation plan submission, the required facility 

wide emissions reduction by calculating the control efficiencies of their selected 

mitigation measures in accordance with 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 specifically 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 measure be approved by the ARB, APCO, and EPA. 

It is important to note that alternate mitigation 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 reductions 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 the permit application, including 

any emission mitigation plan, be publicly noticed with a commenting period of no 

less than thirty (30) days. During this time the ARB, EPA, and stakeholder will have 

the opportunity to view the emission mitigation 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 address quarantine situations. In some 

limited cases all measures may need to be suspended, such as a case where 
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a quarantine prevents equipment, animal waste, nonessential personnel, etc. 

from entering or leaving the facility. However, the decision to suspend any or 

all mitigation measures must be approved on a case by case basis by the 

APCO, ARB, and EPA with input from the appropriate experts, such as 

licensed veterinarians, nutritionists, and government employees. Except for 

poultry molting, the exemption is designed 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 requiring the measures to be suspended or 

implement new mitigation measures to comply with rule requirements. This is 

designed to minimize the time that 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 District to prepare an emission inventory of all 

regulated air pollutants emitted from the facility. 

• Owner/operators would need to submit an update to the permit application at least 

once every three (3) years. 

• The District would need to act on the permit application within six (6) months of 

receipt. 

Section 7.0 Administrative Requirements 

• Recordkeeping 

• Indicates recordkeeping requirements 

• Compliance testing 

• Control devices would need to be initially 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. 
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For Proposed Re-Adoption of Rule 4570

VII. EMISSION REDUCTIONS 

Emissions Reduction Analysis 

The VOC reductions required by the Extreme 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 staff estimated that the VOC 

reduction from Proposed Rule 4570 is about 7,563 tons 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 proposed rule targets VOC reductions but not 

ammonia emissions from CAFs. Ammonia is not a precursor to ozone formation and 

therefore not the pollutant targeted 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 implementation the proposed VOC mitigation measures. The 

ammonia reduction analysis is included in Appendix F of the Final Draft Staff Report. 

VIII. HEALTH EFFECTS 

Respiratory diseases associated with agriculture were one 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, bronchitis, decreased lung function, and depression 

among workers at concentrated animal feeding operations. Of the 331 VOC and 

gaseous compounds found in odorous samples from North Carolina swine facilities, 157 

are known airway irritants; chronic irritation 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 vendors to receive comments on the technical 

aspects and compliance costs of the proposed rule. The comments received from the 

public, affected sources, California Air Resources Board, and United States 

Environmental Protection Agency during the public workshop process and technical 

consultation meetings were incorporated into the proposed rule as appropriate. 
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Comments received and District responses are discussed in Appendix A of the Final 

Draft Staff Report. 

Proposed Rule 4570 and the Final Draft Staff Report including 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 staff 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 regulation 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-effectiveness 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 Appendix 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 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 available retrofit control 

technology. Therefore, the added cost would only be recordkeeping costs, which are 

considered minimal and typically not included 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 repeal of a rule that significantly affects 

air quality or strengthens an emission limitation. The socioeconomic analysis is 

presented in Appendix D of the Final Draft Staff Report. 
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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 State Water Resources Control Board and 

addressed these comments in Appendix A. The initial study and proposed negative 

declaration are presented in Appendix G of the Final Draft Staff Report. District staff 

recommends that the District Governing Board approve the negative 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 Proposed Rule 4570 with the 

corresponding elements of other District rules, federal regulations and guidelines that 

apply to the same source category or type of equipment. The analysis is attached as 

Appendix E of the Final 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 Consider Large CAF Definition, May 2005, 

http://www.arb.ca.gov/regact/lcaf05/isor.pdf. 

3. Archibeque, S.L., Freetly, 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 Sacrificing Performance, Proceedings of The 

Symposium on the State of the Science Animal Manure 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, Agriculture, 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 Demonstration of a Three-Stage Waste Treatment 

Technology, DGH Engineering LTD, 2000, 

http://www.manure.mb.ca/projects/completed/pdf/98-01-31-three-stage-wastetreatment.pdf. 
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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 Bacterium Isolated from an 

Anaerobic Swine Waste Lagoon in Odor Remediation, 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, Transaction of the ASAE, 43(6):1853-1859. 

10. Haith, D.A., ABEN 476 Solid Waste Engineering, Agricultural and Biological 

Engineering Cornell University, Spring 2000, 1999. 

11. Hobbs, P.J. et al, Emissions of Volatile Organic Compounds Originating from UK 

Livestock Agriculture, Journal of the 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, Managing Livestock Wastes to Preserve Environmental Quality, 

Iowa State University Press, 2000. 

14. Ohio State University, Ohio Livestock Manure and Wastewater Management Guide 

Bulletin 604, http://ohioline.osu.edu/b604/b604_15.html. 

15. Ritzman, E.G., and F.G. Benedict, Nutritional Physiology of the Ruminant. 

Washington, D.C. Carnegie Institution of Washington, 1938, 

http://chla.library.cornell.edu/cgi/t/text/text-idx?c=chla;idno=2892302. 

16. Robbins, Janelle, Understanding Alternative technologies for Animal Waste 

treatment, Waterkeepers Alliance, 2004, http://www.waterkeeper.org. 

17. SCAQMD support documents for 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 Agriculture and Trade Policy, October, 2004. 
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Appendix A: Comments and Responses June 15, 2006 

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APPENDIX A 

SIGNIFICANT COMMENTS AND RESPONSES FOR 

PROPOSED RULE 4570 (CONFINED ANIMAL FACILITIES)

June 15, 2006 
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Appendix C: 2006 Final Staff Report submitted with SIP June 18, 2009 

Appendix A: Comments and Responses June 15, 2006 

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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, exemptions, 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 construction 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 also include the language "as soon as 

possible, but no later than" and in some cases the frequency of measures 

should be increased. (EPA) 

Response: Staff believes that wording specifying the maximum period to 

implement measures is more enforceable 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 least expensive of the VOC control 

devices. Based on available scientific data, the high range of biofilter control 

efficiency is approximately 80%; therefore, this was used in the rule. 

6. Comment (Sections 7.1 and 7.2): Records should be consistent with the 

applicable mitigation measures; compliance monitoring and testing should be 

frequent enough to endure continued compliance; demonstrated maintenance 
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should be part of the annual source testing requirements; 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 the 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 California 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 States 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 for Milk Producers Council 

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

PP: Jennifer Meckel and Randell Ishii for Provost & Prichard 

RCI: David Lighthall for the Relational 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 Dairymen 
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Appendix A: Comments and Responses June 15, 2006 

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For Proposed Re-Adoption of Rule 4570

1. Comment: (Rule Section 3.23) Stakeholders would like to remove the 

requirement that the permit description include sufficient information to 

duplicate the measure due to trade secret concerns. (FCF) 

Response: Staff requires sufficient detail, such as listed in the rule, in order 

to develop an emission inventory, as required by Senate Bill 700, and to verify 

compliance. Applicants who would like to protect trade secrets from being 

made available to the general public may request in writing for the District to 

treat such information as “confidential” 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 was 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 the state mandated SIP submitted deadline 

of July 1, 2006. Industry may request 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 justifies 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 required; how the District 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 emission factors. (CAR) 

Response: The District staff held public workshops in March 2006 to present 

and discuss the provisions of Proposed Rule 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 available emission factors. As part 

of the rule development process, a public hearing to adopt the proposed rule 

is scheduled for June 15, 2006. 
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Appendix A: Comments and Responses June 15, 2006 

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4. Comment (Rule Section 5.6 to 5.11):Stakeholders believe that the rule does 

not fulfill BARCT due to the menu format that allows operators to implement 

less stringent controls. (CRP, FMM) 

Response: Staff believes that the least stringent controls in the rule are 

BARCT. More stringent emission controls with very high cost effectiveness 

values for BARCT standards have been included in the rule in order to give 

credit to facility owners/operators that choose to go beyond BARCT. 

5. Comment (Rule Section 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 stringent 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 these 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 Section 5.6 to 5.11): Stakeholders recommend reduction in 

the number of mitigation measures required. (CAR, CCA, CM, FCF, SC) 

Response: The number of required mitigation measures is necessary to 

ensure the District meets its minimum emission reduction commitment in the 

Ozone Plan. Additionally, District staff believes the required measures fulfill 

federal Reasonable Available 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, CAR, 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. 
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8. Comments (Rule Section 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 mitigation measures are feasible for all 

facilities. However, they were included to provide opportunity for 

owners/operators who found these measures feasible to implement in their 

facilities. Some measures may not be feasible for any facilities at this time 

based on existing infrastructure and costs, 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 allow flexibility for owners/operators to 

implement such measures at any time they determine to be feasible and cost 

effective. 

9. Comment (Rule Section 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 Regional Water Quality Board is drafting 

waste discharge requirements (WDR) for dairies. Since these will not be finalized 

prior to Rule 4570 adoption, staff 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 requirements. The differences between the rules 

are due to the different goals, relevant science available, and jurisdictions of the 

agencies. Pursuant to state H&SC, staff performed a Rule Consistency Analysis 

that compares the provisions of Proposed Rule 4750 with the elements of other 

District rules, federal rules and regulations, other government agencies’ regulations 

that apply to the same source category. Please refer to Appendix E of the Final 

Draft Staff Report for a detailed 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 measures were RWQB requirements in some 

cases. However, In the event that Rule 4570 requirements are less stringent than 

required by another agency, owners/operators are obligated to comply with the 

more stringent of the requirements. 

10. Comment (Rule Section 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 measures in the rule that do not include 

composting. Staff was unable to find sufficient information regarding VOC 

reductions from management practices for windrow composting to justify its 

inclusion in the emission mitigation measure list. However, facilities may 

submit it for approval as an alternative mitigation measure. 
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Appendix A: Comments and Responses June 15, 2006 

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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, swine, and poultry are all different 

animals with slightly different control measures. The measures available to one 

type of facility are not always available to other at the same cost—thus the different 

requirements. 

12. Comment (Rule Section 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 high 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 the 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, maintenance 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 that 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 credit 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 receive 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, then 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 Section 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 research 
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Appendix A: Comments and Responses June 15, 2006 

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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 with increased milk production, decreased 

abortions, and decreased calving intervals, thus for their facility it was costeffective. Such benefits have been seen in several research studies. Inclusion of 

mitigation measures does not constitute 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 Avila the cost to retrofit a typical 

dairy LCAF would be well over $700,000. Thus 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 would cause significant NOx emissions. 

Finally, the existing enclosed facilities are in states with cooler temperatures and 

on smaller facilities, therefore staff can not determine that this method would be 

feasible and cost-effective in our district and on dairies with over 1,000 animals. 

However, the District would like to encourage implementation of new and 

promising control technologies thus included 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 $500,000 for the typical dairy. While they 

may offset the cost with electricity generation, there are significant challenges to 

selling electricity and it is not feasible for 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 facilities to suspend use of mitigation 

measures should be decreased. (AU, CRP, FMM) 

Response: At the time of the rule development, 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 is 
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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 least once every eighteen months. The 

inspection will include analysis of the 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 prior to the manure 

being removed from the housing. Furthermore, since the manure is being 

removed from a relatively VOC uncontrolled area (housing) to a VOC 

controlled area (storage piles, digesters, lagoons, or incorporated into the 

soil), the VOC are not simply being moved 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 years consistent with the permit review 

time; expressed concern that recordkeeping requirements are burdensome; 

and would like coordination of reporting requirements with other agencies. 

(CAR, CCA, CDC, CFB, FCF, HR, SC, WUD) 

Response: Five years is consistent with other 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 maintained for five years. In order to 

maintain consistency, staff believes that five (5) years is an appropriate time 

period and not overly burdensome. Additionally, 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 for compliance staff to ensure all 

facilities subject to the rule are complying; without a recordkeeping 

requirement for number of animals, it would not be possible for a facility to 
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prove to an inspector that they are exempt 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 emission inventory. 

However, this not required at this time 

 

24. Comment (Rule Section 7.2): Stakeholders recommended clarification on 

what the source testing requirements apply to; clarification of test methods 

required; modification of the monitoring requirements; and question the test 

methods. (CAR, CCA, CCC, CDC, CFB, DA, FCF, HR, MPC, SC, WUD) 

Response: Staff modified the section to clarify that the 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. Specific methods are not mandated in all 

cases in order to allow the owners/operators to choose the method most cost 

effective for their operation. 
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Appendix A: Comments and Responses June 15, 2006 

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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 may have additional requirements for 

confined animal facilities; require that the appropriate Regional Water Quality 

Board be notified when implementing measures 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 jurisdiction 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 Report staff notes that some measures are 

not feasible for all facilities due to limitations 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 choose the option that makes the most 

environmental sense for their particular facility. 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 Staff Report for additional 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 extension to the comment 

deadline. (CRP, SWR) 

Response: Due to the tight deadline mandated 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 for 
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incorporation into the staff report; 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 calculations should be changed. (PP, RS) 

 Response: The Dairy Permitting Advisory Board Report (DPAGR) and initial 

APCO report (APCOR) on the Dairy Permitting Advisory Board's findings in 

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

additional research has become available 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 dairy was 21.7 lb/hd/yr. Based on the 

Conservation Management Practices 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 proposed projects are 

completed." This appears to be a result of a backlog of permit applications 

and exceeds previous known growth rates for the dairy industry; industry 

estimates of growth; and CAR's analysis. 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 milking cow growth rates over 25% 

according to the USDA/NASS census data. According to the USDA/NASS 

census data the inventory of milk cows in the SJVAB increased 6.9% from 

2004 to 2005, if this trend continued it would result in over 20% growth in the 

San Joaquin Valley. 

32. Comment: Page 34 and 35 of the Final Draft Staff Report states that properly 

designed and operated lagoons and phototrophic (aerobic) lagoons emit less 
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VOCs that overloaded lagoons, but then state that it is beyond BARCT to require 

owners/operators not to overload their lagoon (CRP). 

Response: Please refer to page 34 and 35. Phototrophic 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 electrical 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 surface 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 operators 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 the rule, thus their additional cost and the associated 

VOC reductions are not solely due 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 avoid counting VOC reductions attributable to 

measures facilities were utilizing before rule adoption. (AU, CRP, FMM) 

Response: Since facilities could cease utilization 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 of 
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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 conservative staff utilized this value. Based on 

conversations with California State University Fresno researcher Matt Beene, staff 

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

in the research used to determine emission factors fed a diet based on NRC 

guidelines. Furthermore, staff believes that, based on conversations with 

producers, the majority of facilities do not feed a strict NRC based diet, instead 

they tend to modify it for various reasons 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 efficiency 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 designing 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 control 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 similarly to biofilters. (CRP) 

 Response: Biofilters are organic media, similar to what is found in fields, 

particularly those that plow under their crop residue. Furthermore several research 

projects, please see the references in the Final Draft Staff Report, show decreased 

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

that it is reasonable to consider 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 that 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) 
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 Response: As required by the CH&SC 40728, the District considered the 

socioeconomic impacts of this rule and mitigated it to the extent feasible. Please 

see Appendix C of the Final Draft Staff Report. The lowest 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 expected to result in a loss of approximately 

40 jobs. Therefore, the lowest cost options are beyond what typically would be 

considered for a BARCT rule. Although, considering the significance and quantity 

of emissions, staff believes this is reasonable for BARCT, but beyond this would 

not be. 
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Appendix B: VOC Emission Reductions June 15, 2006 

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APPENDIX B 

EMISSION REDUCTION ANALYSIS FOR 

PROPOSED RULE 4570 (CONFINED ANIMAL FACILITIES)

June 15, 2006 
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For Proposed Re-Adoption of Rule 4570

EMISSION REDUCTION ANALYSIS 

I. SUMMARY 

This appendix details the estimated emission 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 results of the detailed calculations, which are 

shown later in this section. Based on this data, the rule should generate reductions of 

approximately 20,919 tons VOC 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 cattle 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 majority of poultry, goats, sheep, and other animals are raised in 

facilities below the "large CAF" definition. District staff performed a preliminary VOC 

emissions reduction analysis and a preliminary cost effectiveness analysis for proposed 

Rule 4570 (Confined Animal Facilities) based on the information that is currently 

available. 

The proposed rule would require facilities above 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 used as the applicability 

threshold to satisfy state and federal requirements. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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Table 2 

Summarizes the Number of Mitigation Measures 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 (measures a, b, and c) each one was counted 

separately for the purpose of calculating the 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 enforcement. The permit application shall be 

submitted by December 15, 2006. In accordance with state law, the emission mitigation 

measures shall be implemented within one year after the permit issuance date. 

Table 3 

Summarizes the Emissions and Reductions 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 0 
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For Proposed Re-Adoption of Rule 4570

III. EMISSION REDUCTION ANALYSIS

A. Background 

In performing the analysis, several assumptions and abstractions from reality were 

made to reflect conservative emission reduction results. These include: 

• All mitigation measures achieve creditable VOC reductions from all facilities that 

use the mitigation measures. Although staff noted that many 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 factor. The reason for this is because, 

without Rule 4570, the facilities could cease use of the mitigation measures at 

any time. Thus, the rule achieves reductions by prohibiting the owner/operator 

from ceasing to use or going below Best Available Retrofit Control Technology 

(BARCT) for VOC control. 

• Facilities will only implement the number of mitigation measures required by 

Proposed Rule 4570. Staff acknowledges that industry may do more than is 

required. Since the additional mitigation measures that 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 appropriate to claim such reduction or 

costs in the Rule 4570 development process. 

• Facilities will choose the mitigation measures that are lowest cost BARCT 

options. Again, staff acknowledges that facilities may choose more costly 

options. Additionally many existing facilities 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 more 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 practices. The District has conservatively 

assumed a minimal 10% control effectiveness. As information becomes 

available, it will be added to this methodology. Additional air quality benefits and 

control effectiveness for these practices 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% causes the emission factor for the lagoon, 

where the manure is processed, to have 10% less emissions. 

• Approximately 29% percent of the dairies have no freestalls, based on CDFA 

data provided by Mike Francesconi. 
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B. Excluded Activities and Facilities 

Based on the assumptions above, staff analyzed the cost effectiveness of least 

expensive BARCT options that owners/operators would likely 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 those 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. 
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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 in 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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milking center; liquid manure handling; and land application subtotal to the current 

emission factors for permitting 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 counted are the solid bedding storage piles and 

the feed piles outside of the animal housing. Since there is research documenting 

emission from and VOC control options for these 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 whole by the following equation: 

Weighted average= Emission factor for facilities 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 

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

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For Proposed Re-Adoption of Rule 4570

Table 5: Weighted Emissions 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 the excess nutrients fed to the animals. Based 

on research suggesting that nitrogen content in feed is directly proportional to 

nitrogen content in manure, staff believes that feeding according to the NRC 

guidelines, which minimizes excess nutrients in the diet, would reduce VOC 

emissions. Since there is little data quantifying 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 exiting the animal and thus 

being treated in each animal waste system. It will also reduce the emissions from 

feed in the housing and stockpiles because there will be less 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 nutrients, such as protein, in feed would not increase costs 
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significantly. Any additionally labor employed 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 moisture. Since the microorganisms that 

degrade organic material to form VOCs require moisture, this is expected to reduce 

the VOC emissions from the feed storage. Since there is little data quantifying this 

reduction, the 10% default is assumed. However, 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 (emissions 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 measures for cleaning feed from housing

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

from the feed to the atmosphere, and anaerobic digestion due to wet conditions and 

thick depths of animal waste. Data suggests that these practices would minimize 

VOC emissions, however there are no peer-reviewed articles that quantify this. 

Therefore, staff assumed a default reduction of 10% for each measure. However, it 

only affects the emissions from feed and these emissions were already reduced by 

Option 1 and Option 2. 

Option 3 Reductions = 0.63 lb/hd-yr (emissions from feed) x 90% (emissions 

remaining after implementing Option 1) x 90% (emissions remaining after 

implementing Option 2) x 10% (control efficiency) = 0.05 lb/hd-yr 

Option 4 Reductions = 0.63 lb/hd-yr (emissions 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) 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-yr 
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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 moisture, surface area for VOCs to move 

from the feed to the atmosphere, anaerobic digestion due to wet conditions, and 

excess nutrients in animal waste due to silage practices. Data suggests that these 

practices would minimize VOC emissions, however there are no peer-reviewed 

articles that quantify this. Therefore, staff assumed a default reduction of 10% for 

each measure. However, it only affects the emissions from feed and these 

emissions were already reduced by Option 1. 

Option 5 Reductions = 0.63 lb/hd-yr (emissions 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 calculate the emission factor this practice was being done. 

Therefore, the baseline assumes 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 freestalls after each milking or flush more 

frequently than milking and rake, harrow, scrape, or grade bedding at least once 

every two weeks

Typically, facilities flush once per milking or scrape once a day (once every two 

milkings). Typically, facilities clean 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 freestalls by 50%. The freestall emissions 
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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% (emissions 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 moisture 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 quantify 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 implementing 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 implementing Option 9) x 90% (emissions 
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remaining after implementing Option 10) x 90% (emissions remaining after 

implementing Option 11) x 10% (control efficiency)= 0.01 lb/hd-yr 

Option 13 Reductions = 0.16 x 90% (emissions remaining after implementing Option 

1) x 90% (emissions remaining after implementing Option 9) x 90% (emissions 

remaining after implementing Option 10) x 90% (emissions remaining after 

implementing Option 11) x 90% (emissions remaining 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 implementing Option 9) x 90% (emissions 

remaining after implementing Option 10) x 90% (emissions remaining after 

implementing Option 11) x 90% (emissions remaining after implementing Option 12) 

x 90% (emissions remaining after implementing 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 (Option 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 regarding the amount of emissions from the 

manure storage piles, therefore staff conservatively estimated the separated solids 

and the manure piles emit approximately the same amount of VOC. Since there is 

little data regarding reductions staff assumed a default reduction of 10% for each 

mitigation measure. The reduction per measure is: 

Option 16 Reductions = 0.2 lb/hd-yr (piles) x 90% (emissions remaining after 

implementing Option 1) x 10% = 0.02 lb/hd-yr reductions. 

Option 17 Reductions = 0.2 lb/hd-yr (piles) 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. 
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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, 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 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 EPA, swine emit 63.5% of the volatile solids that cattle 

do. Therefore, in order to be conservative, 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 emissions 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 emission 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. Research suggests biofilters range in efficiency 

from 10% to 90% depending on how they are maintained. Conservatively staff 

assumed 50% control. The baseline emissions 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% (control efficiency) = 2.07 lb/hd-yr 

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

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

9. TOTAL REDUCTIONS 
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Appendix B: VOC Emission Reductions June 15, 2006 

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The total percent reductions can be calculated by summing the percent reductions 

for each mitigation measure above. 

Total Reductions = 36% 

E. Beef Feedlot Control Efficiencies 

Emissions from liquid manure handling was excluded because it is not expected that 

there are existing beef feedlots 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 emissions, and land application emissions. 

Based on American Society of Agricultural and Biological Engineers (ASAE) Publication 

D384.1, manure from beef cattle 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 manure is a function of diet and the amount of 

manure, emission factors for dairy cattle in Table 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 numbers 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 subtotal 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 emissions from each animal unit, but the numbers 

are based on the best available science. Since the 11.1 lb/hd-yr factor was used for 

permitting, this was used in all calculations that 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 feed 
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piles outside of the animal housing. Since there is research documenting 

emissions from and VOC control options for these sources, staff estimated the 

emissions from these sources by using data from Schmidt's research for dairy 

cattle, adjusted to be applicable 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 the excess nutrients fed to the animals. Based 

on research suggesting that nitrogen content in feed in directly proportional to 

nitrogen content in manure, staff believes 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 precursors being fed to the animal (entering the 

animal) it will reduce the VOC precursor exiting the animal and thus being treated in 

each animal waste system. It will also reduce the emissions from feed in the 

housing because there will be less VOC precursors in the feed, which could 

eventually decompose. Therefore, the 10% reduction was applied 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 moisture. Since the microorganisms that 

degrade organic material to form VOCs require moisture, this is expected to reduce 

the VOC emissions from the feed storage. Since there is little data quantifying this 

reduction, the 10% default is assumed. However, 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 (emissions 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% 
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Appendix B: VOC Emission Reductions June 15, 2006 

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Option 3, 4, and 5: Three mitigation measures for cleaning feed from housing

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

from the feed to the atmosphere, 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. Therefore, staff assumed a default reduction of 

10% for each measure. However, it only 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 (emissions from feed) x 90% (emissions 

remaining after implementing Option 1) x 90% (emissions remaining after 

implementing Option 2) x 10% (control efficiency) = 0.103 lb/hd-yr 

Option 4 Reductions = 0.43 lb/hd-yr (emissions 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 (emissions 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 moisture, surface area for VOCs to move 

from the feed to the atmosphere, 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. Therefore, staff assumed a default reduction of 

10% for each measure. However, it only affects the emissions from feed and these 

emissions were already reduced by Option 1. 
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Reductions Option 6= 0.43 lb/hd-yr (emissions 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 moisture 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 quantify this. Therefore, staff assumed a 

default reduction of 10% for each measure. The reduction per measure is: 

Option 7 Reductions= 3.3 x 90% (emissions remaining 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 implementing Option 7) x 10% (control efficiency)= 

0.27 lb/hd-yr 

Option 9 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 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% (control 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 remaining 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 remaining after implementing Option 10) x 
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90% (emissions remaining after implementing 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 remaining after implementing Option 10) x 

90% (emissions remaining after implementing 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 through 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 regarding the amount of emissions from the 

manure storage piles, therefore staff conservatively estimated the separated solids 

and the manure piles emit approximately the same amount of VOC. Since there is 

little data regarding reductions staff assumed a default reduction of 10% for each 

measure. The reduction per measure is: 

Option 14 Reductions = 0.1 lb/hd-yr (piles) x 90% (emissions remaining after 

implementing Option 1) x 10% = 0.01 lb/hd-yr reductions. 

This is out of a total emission 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 biofilters and soil are organic 

media with significant microbial populations and airflow. Research suggests 

biofilters range in efficiency from 10% to 90% depending on how they are 
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maintained. Conservatively staff assumed 50% control. The baseline emission from 

crop application is 2.5 lb/hd-yr. The seven moisture 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 use 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% (control efficiency) = 1.13 lb/hd-yr 

This is out of a total emission 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 calculated by summing the percent reductions 

for each mitigation measure above. 

Total Reductions = 36% 

F. Other Cattle Control Efficiencies 

A significant number of these animals are being raised for replacement animals on 

dairies, as veal, or as stock for beef feedlots. 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 efficiency 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 housing
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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: All 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 calculated 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 report 2.4 lb/hd-yr of emissions are from 

lagoons. Therefore, 4.6-2.4=2.2 lb/hd-yr are from feed, housing, and land application. 

Since there is little data quantifying the contribution of each, it is assumed that 

approximately 50% of the emissions 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 other 50% are being attributable to manure. Currently, there 

are no swine facilities above the rule threshold that stockpile manure or utilize a dry 

manure handling system. Therefore, these options will not be considered in this 

analysis. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix B: VOC Emission Reductions June 15, 2006 

C - 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 the excess nutrients fed to the animals. Based 

on research suggesting that nitrogen and protein content in feed is directly related to 

VOC emissions from manure, staff believes that feeding according to the NRC 

guidelines, which minimizes excess nutrients in the diet, would reduce VOC 

emissions. Since there is little data conclusively quantifying this reduction, the 10% 

default is assumed. Since it reduces the VOC precursors in the 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 moisture. Since the microorganisms that 

degrade organic material to form VOCs require moisture, this is expected to reduce 

the VOC emissions from the feed storage. Since there is little data quantifying this 

reduction, the 10% default is assumed. However, 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 (emissions 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 moisture, surface area for VOCs to move 

from the feed to the atmosphere, 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. Therefore, staff assumed a default reduction of 

10% for each measure. However, it only 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 

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

Appendix B: VOC Emission Reductions June 15, 2006 

C - 94 Final Staff Report with Appendices 

For Proposed Re-Adoption of Rule 4570

Option 3 Reductions = 0.55 lb/hd-yr (emissions from feed) x 90% (emissions 

remaining after implementing Option 1) x 90% (emissions remaining after 

implementing Option 2) x 10% (control efficiency) = 0.04 lb/hd-yr 

Option 4 Reductions = 0.55 lb/hd-yr (emissions 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) x 

10% (control efficiency) = 0.04 lb/hd-yr 

Option 5 Reductions = 0.55 lb/hd-yr (emissions 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) 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 housing measures to clean housing, manage manure 

depth, and minimize moisture

These are intended to minimize moisture 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 quantify this. Therefore, staff assumed a 

default reduction of 10% for each measure. The reduction per measure is: 

Option 6 Reductions = 2.2 lb/hd-yr (emissions 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 (emissions 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 (emissions 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 10% (control efficiency) = 0.16 lb/hd-yr 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix B: VOC Emission Reductions June 15, 2006 

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Option 9 Reductions = 2.2 lb/hd-yr (emissions 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 remaining after Option 

8) x 10% (control efficiency) = 0.14 lb/hd-yr 

Option 10 Reductions = 2.2 lb/hd-yr (emissions 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 remaining 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 specific 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 phototrophic lagoons are typically found in 

lagoons utilizing a solid separator, NRCS guidelines for anaerobic lagoon design, 

and microaerobic nutrient management. The baseline 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 emission 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 Report submitted with SIP June 18, 2009 

Appendix B: VOC Emission Reductions June 15, 2006 

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For Proposed Re-Adoption of Rule 4570

These practices are intended to rapidly land incorporate the manure or wastewater. 

The soil is expected to act as a biofilter since it is an organic media with significant 

microbial populations and airflow. Research suggests biofilters range in efficiency 

from 10% to 90% depending on how they are maintained. Conservatively staff 

assumed 50% control. The baseline emission from crop application is 1.1 lb/hd-yr. 

The moisture 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 use 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: 

Option 12 & 13 Reductions = 1.1 lb/hd/year x 90% (emissions remaining after 

implementing Option 1) x 20% (emissions remaining after implementing Option 11) x 

50% (control efficiency) = 0.10 lb/hd-yr 

This is out of a total emission 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 calculated 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 Report submitted with SIP June 18, 2009 

Appendix C: Cost Effectiveness Analysis June 15, 2006 

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For Proposed Re-Adoption of Rule 4570

 

APPENDIX C 

COST EFFECTIVENESS ANALYSIS FOR 

PROPOSED RULE 4570 (CONFINED ANIMAL FACILITIES)

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

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

Appendix C: Cost Effectiveness Analysis June 15, 2006 

C - 98 Final Staff Report with Appendices 

For Proposed Re-Adoption of Rule 4570

COSTS AND COST EFFECTIVENESS ANALYSIS 

I. SUMMARY 

Proposed Rule 4570 (Confined Animal Facilities) would require owner/operators of 

confined animal facilities (CAF) to reduce VOC emissions from CAF. As presented in 

Appendix B of this Staff Report, annual VOC emissions from CAF are estimated to be 

over 27,000 tons per year (tpy). Draft VOC control requirements would require 

owner/operators to implement various mitigation 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 practices are used on all of the facilities. In fact, most facilities 

do not use all of the measures. This report presented the expected additional costs for 

existing facilities to implement additional controls 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 ton 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 available retrofit control 

technology. Therefore, the added cost would only be recordkeeping costs, which are 

considered minimal and typically not included in the cost effectiveness analysis. 

II. REQUIREMENTS OF ANALYSIS 

The California Health and Safety Code 40920.6(a) requires the San Joaquin Valley 

Unified Air Pollution Control District to conduct both an absolute cost effectiveness 

analysis and an incremental cost effectiveness analysis of available emission control 

options before adopting each Best Available Retrofit Control Technology (BARCT) rule. 

The purpose of conducting a cost effectiveness analysis is to evaluate the economic 

reasonableness of the pollution control measure or rule. The analysis also serves as a 

guideline in developing the control 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 per 
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For Proposed Re-Adoption of Rule 4570

year. This report presents the 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 tons of VOC reduced per year, between two 

progressively more effective control options or technologies. Incremental cost 

effectiveness compares the differences in costs and the differences in emissions 

reductions of the two candidate control options. Incremental cost effectiveness does 

not reveal the emission reduction potential of the control options, merely the additional 

cost of adding the next most effective control to a given control measure. Unlike the 

absolute cost effective analysis that identifies the control option with the greatest 

emission reduction, incremental cost effectiveness 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 comparable 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 required minimum number mitigation measures 

from a list of multiple measures or developing mitigation measures of their own not 

specified in the rule provided they could demonstrate 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 granted for such alternative mitigation 

measures. In general, since owners/operators have the flexibility to choose from a list 

of mitigation measures, staff believes owners/operators will likely choose the option with 

the best cost effectiveness for his/her particular 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 Department of Food and Agriculture, industry 

representatives, and venders. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix C: Cost Effectiveness Analysis June 15, 2006 

C - 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 determine 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 believes most if not all large facilities 

already have their grain in such structures. 

COST = $0.00 

c. Feed cleaning practices 

Many facilities already implement 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 weeks and $3.30 per hour maintenance and 

operating costs for equipment. Staff assumed 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 associated 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 approximately $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% (adjustment 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 facilities 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 measure 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 Report submitted with SIP June 18, 2009 

Appendix C: Cost Effectiveness Analysis June 15, 2006 

C - 101 Final Staff Report with Appendices 

For Proposed Re-Adoption of Rule 4570

COST = $5.30 per cow x 71% (adjustment factor considering only 

71% of facilities will implement this 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 approximately eight times that of 

cleaning freestalls. However, based on permit database 

information, 90% of the facilities 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, the cost is considered not 

significant. 

COST = $ 0.00 

8. Land application practices 

a. Dry solid manure or only apply liquid manure at a rate at which it 

will be absorbed into the soil. These 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 approximately 42% of the emission 

factor of 21.0 lb/hd/yr. Therefore the cost 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 determine 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 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix C: Cost Effectiveness Analysis June 15, 2006 

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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 believes most if not all large facilities 

already have their grain in such structures. 

COST = $0.00 

c. Feed cleaning practices 

Many facilities already implement 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 weeks and $3.30 per hour maintenance and 

operating costs for equipment. Staff assumed 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 associated 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 1/13th the 

number of times as dairy, the cost is expected to be 1/13th 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 only set a new time schedule for land 

applying the manure, it would not require 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 liquid manure at a rate at which it 

will be absorbed into the soil. These 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. 
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Appendix C: 2006 Final Staff Report submitted with SIP June 18, 2009 

Appendix C: Cost Effectiveness Analysis June 15, 2006 

C - 103 Final Staff Report with Appendices 

For Proposed Re-Adoption of Rule 4570

The total additional cost to implement new controls is approximately $9 per hd per year. 

From Appendix B the total reductions are approximately 42% of the emission factor of 

11.1 lb/hd/yr. Therefore the 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 determine 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 believes most if not all large facilities 

already have their grain in such structures. 

COST = $0.00 

c. Feed cleaning practices 

Many facilities already implement 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 weeks and $3.30 per hour maintenance and 

operating costs for equipment. Staff assumed 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 associated 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 approximately $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% (adjustment 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 measure 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 

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Appendix C: Cost Effectiveness Analysis June 15, 2006 

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COST = $5.30 per cow x 71% (adjustment factor considering only 

71% of facilities will implement this 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 facilities 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 covered. 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, the cost is considered not 

significant. 

COST = $ 0.00 

7. Land application practices 

a. Dry solid manure or only apply liquid manure at a rate at which it 

will be absorbed into the soil. These 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 reductions are approximately 42% of the emission 

factor of 7.08 lb/hd/yr. Therefore 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 operation 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 facility will comply with Draft Rule 

4570 requirements with few significant operational or physical changes. Based on 

current practices, the facility is expected to choose the following mitigation options from 

the draft rule: 
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Appendix C: 2006 Final Staff Report submitted with SIP June 18, 2009 

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1. Feed and silage practices: 

a. Feed according to National Research Council (NRC) guidelines: 

No significant cost because the facility 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 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. 

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 roofed with drainage outside of the housing and the floors 

are slatted with daily flushing of the pits underneath the slats, staff believes that 

the facility already complies with this mitigation measure. 

COST = $0.00 

d. Remove spilled feed from the facility at least once every fourteen 

days. 

The feed is transported in a closed system from the grain storage 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 expect spilled feed, within fourteen days, 

to fall between the slats and be removed 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 ratios 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 there would be no additional trips. Any 

additional costs for grinding more frequently 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 animal waste depth does not exceed 

eight (18) inches. 

The facility already implements this measure. 
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COST = $0.00 

c. Ensure that water from troughs 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 inspecting 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 for a skilled agriculture worker listed 

in the US Bureau of Labor Statistics) with 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/house 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, there 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 approximately 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. 
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APPENDIX D 

SOCIOECONOMIC ANALYSIS FOR 

PROPOSED RULE 4570 (CONFINED ANIMAL FACILITIES)

June 15, 2006 
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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 • Sacramento, California 95814 • (916) 441-0323 

www.adeusa.com 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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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...................................................................................................... 121 
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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, 1994-2004 ($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 California 1994-2004 ($2004).......... 131 

15 Cattle and Calves Industry Trends: All Other Cattle: San Joaquin 

Valley Region and State of California 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.............................. .139 
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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 Rule 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 Additional 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 stakeholders; 9.6 percent of the net profits of large 

CAF dairy stakeholders; 13.0 percent of the net profits 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 impact 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 primarily labor costs (e.g. labor for increased cleaning; 

inspection for leaks; covering of manure piles; and covering of silage piles). Therefore, the rule 
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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 housing 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 manure, 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 businesses 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 large 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 equivalents 
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2. INTRODUCTION 

This report describes the socioeconomic 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 socioeconomic 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 Basin 
SAN 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 Attainment Plan and the 2002 and 

2005 Rate and Progress Plan (ROP) identify the need to address 

VOC emissions from confined animal 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 facilities (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.” 
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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 Development Department (EDD) Labor 

Market Information Division. Global trends data is available from 

the United Nations Food and Agriculture 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 analysis shows what proportion of 

profits the compliance costs represent. 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 effects 

of 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 incorporated the methodologies 
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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 significant 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 percent to a ROE of 9 percent) as a 

threshold for a finding of no significant, adverse impact on either 

competitiveness or jobs seems reasonable or even conservative.” 
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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 whole, 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 Valley 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 tremendous 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 percent (or approximately 2.0 percent annually), 

from 3.0 million in 1994 to 3.6 million in 2004. While 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 following section on regional economic trends, the 

demographic changes that occurred in the San Joaquin Valley region during the 1990s significantly 

influenced the economy of this eight-county region. 
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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 local 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; purchases of fixed assets, goods, and services; and generation of more jobs 

and wealth. 

The economic base is typically comprised of industries 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 function 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 Joaquin 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 within 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 employed the most workers as a proportion of total 

employment in the region. As Table 2 shows, excluding 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. 
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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. 
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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 percent, 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 the 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 cumulative 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. 
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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 context, the discussion below starts with broad global 

and national trends, focusing particularly on world 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. These 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 United States dropped out of the UN FAO’s 2004 list of 

top twenty exporters of milk. US cheese exports is also small at 2.6 percent of the global market. In 

other words, US milk and cheese producers sell their 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 number cattle in the export market also declined 
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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 livestock producers. Canada is the largest market of 

US exports. 

World exports of chicken by the twenty leading countries increased modestly by one percent 

annually between 1999 and 2004, although American 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, world chicken prices are less than American prices of 

$1.71, which may also partly explain the decline in American exports. 
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 F

TABLE 4 

Milk and Cheese Trends: United States and Top Twenty Leading Exporters 1994-2004 ($2004) 

1994 1999 2004 94-99 99-04 94

US 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%  Value $2,276,796,892 $2,907,676,944 $2,338,231,000 5.0% -4.3%  Value per ton $805 $740 $458 -1.7% -9.2% US exports Cheese Metric tons 24,761 43,121 62,371 11.7% 7.7%  Value $141,648,453 $461,068,729 $201,410,000 26.6% -15.3%  Value per ton $5,721 $10,692 $3,229 13.3% -21.3% Top 20 Exporters Cheese Metric tons 2,254,202 2,649,151 3,537,665 3.3% 6.0%  Value $13,542,828,867 $17,573,353,850 $14,131,749,000 5.3% -4.3%  Value per ton $6,008 $6,634 $3,995 2.0% -9.6% Source: Applied Development Economics, based on UN Food and Agriculture Organization 

TABLE 5 

Cattle Export Trends: United States and Top Twenty Leading Exporters 1994-2004 ($2004) 

1994 1999 2004 94-99 

US Exports Aggregate 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 Exporters Aggregate Value $6,853,666,560 $4,758,106,126 $4,076,059,000 -7% 

Number of heads 7,942,994 8,105,452 7,199,065 0% 

 Per head Price $863 $587 $566 -7% Source: Applied Development Economics, based on UN Food and Agriculture Organization 
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 F

TABLE 6 

Chicken Industry Export Trends: United States and Top Twenty Leading Exporters 1994-2004 ($

1994 1999 2004 94-99 

US Exports Aggregate Value $167,963,235 $127,290,942 $66,514,000 -5%  Number of heads 62,443,000 45,159,000 39,011,000 -6%  Per head Price $2.69 $2.82 $1.71 1% Top 20 Exporters Aggregate Value $1,001,053,610 $857,081,816 $919,656,000 -3% 

Number of heads 510,529,000 552,076,000 734,069,000 2% 

 Per head Price $1.96 $1.55 $1.25 -5% Source: Applied Development Economics, based on UN Food and Agriculture Organization 

TABLE 7 

Swine Industry Export Trends: United States and Tope Twenty Leading Global Exporters 1994-2004 

1994 1999 2004 94-99 

United States Aggregate Value $59,629,458 $35,126,192 $32,140,630 -10%  Number of heads 386,380 348,109 337,983 -2%  Per head Price $154 $101 $95 -8% Top 20 Exporters Aggregate Value $69,869,506 $38,882,171 $39,293,974 -11% 

Number of heads 463,000 399,000 352,000 -3% 

 Per head Price $151 $97 $112 -8% Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data incudes federal subsidies (EWG. Farm Subsid
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C - 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 slightly 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 relatively 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 billion 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.
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TABLE 8 

 Dairy Industry Trends: United States, 1994-2004 

1994 1999 2004 94-99 

Nation Nos. of Milk Cows 7,861,833 7,734,333 7,712,962 -0.3%  Pounds of Milk 129,712,000,000 $140,062,000,000 147,373,402,231 2% 

Average Production 16,499 18,109 19,107 2% 

Source: Applied Development Economics, based on USDA ERS Economic Outlook 

TABLE 9 

Cattle Industry Trends: United States, 1994-2004 

1994 1999 2004 94-99 99-04 94

Milk cows 9,507,000 9,128,000 8,990,000 -0.8% -0.3% Dairy heifers 4,125,000 4,069,000 4,020,000 -0.3% -0.2% Beef cows 34,603,000 33,750,000 32,861,000 -0.5% -0.5% Beef Heifers 6,364,000 5,535,000 5,518,000 -2.8% -0.1% Other heifers 9,104,000 10,170,000 9,806,000 2.2% -0.7% Steers >500 lb. 17,086,000 16,891,000 16,277,000 -0.2% -0.7% Bulls 2,312,000 2,281,000 2,206,000 -0.3% -0.7% Calves 17,873,000 17,290,000 15,210,000 -0.7% -2.5%  Total Cattle 100,974,000 99,114,000 94,888,000 -0.4% -0.9% Source: Applied Development Economics, based on USDA ERS Economic Outlook 
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TABLE 10 

Unit Price of Cattle, 1994-2004 ($2004) 

1994 1999 2004 94-99 99-04 94-04 

Cattle prices 

 Steers, Choice, 11-13 cwt 

 Texas 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 Falls 

 Utility 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 City  Steers: Med. #1 

 500-550 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. #1 

 450-500 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 11 

Trends in Broilers: United States 1994-2004 ($2004) 

1994 1999 2004 94-99 99-04 

Number of heads 7,017,540,000 8,146,010,000 7,065,621,427 3.0% -2Pounds 48,456,290,168 50,773,370,162 34,083,000,000 1% Gross Value $16,939,960,631 $18,813,273,477 $24,198,930,000 2% Value per head $2.41 $2.31 $3.42 -1% Value per pound $0.52 $0.46 $0.71 -2% 
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TABLE 12 

Swine Trends: United States, 1994-2004 ($2004) 

1994 1999 2004 94-99 99-04 

Number of heads 59,738,000 59,335,000 60,975,000 -0.1% 0Per head Price: Sow $47.48 $23.95 $28.24 -13% Per head Price: Lean Hogs $62.57 $42.28 $39.45 -8% Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data incudes federal subsidies (EWG. Farm Subsid
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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 and 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 are beef cattle only. Because beef 

cattle are a small portion of the overall 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 million 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).
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TABLE 13 

Dairy Industry Trends: San Joaquin Valley Region and State of California, 1994-2004 ($2004) 

1994 1999 2004 94-99 

Region Aggregate Value $2,800,920,159 $3,614,087,130 $4,321,127,613 5.2%  Production (Cwt) 164,346,457 216,804,199 292,249,472 5.7%  Per Unit Price $17.01 $16.63 $14.72 -0.5% State Totals Aggregate Value $3,752,975,256 $4,600,277,044 $5,304,938,310 4.1%  Production (Cwt) 218,037,547 274,337,967 358,445,714 4.7%  Per Unit Price $17.18 $16.72 $14.73 -0.5% Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data includes federal subsidies (EWG. Farm Subsi

TABLE 14 

Cattle and Calves Industry Trends: Beef Cattle Only: San Joaquin Valley Region and State of Calif

1994-2004 ($2004) 

1994 1999 2004 94-99 

Region Aggregate Value $148,326,932 $126,636,712 $115,441,165 -3.1%  Number of heads 170,470 195,578 162,800 2.8%  Per head Price $870 $648 $709 -5.7% State Totals Aggregate Value $791,190,182 $542,886,300 $544,104,000 -7.3% 

Number of heads 841,146 810,000 720,000 -0.8% 

 Per head Price $941 $670 $756 -6.6% Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data includes federal subsidies (EWG. Farm Subsi
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TABLE 16 

Swine Industry Trends: All Other Cattle: San Joaquin Valley Region and State of California 

1994-2004 ($2004) 

1994 1999 2004 94-99 

Region Aggregate Value $59,629,458 $35,126,192 $32,140,630 -10.0%  Number of heads 386,380 348,109 337,983 -2.1%  Per head Price $154 $101 $95 -8.1% State Totals Aggregate Value $69,869,506 $38,882,171 $39,293,974 -11.1% 

Number of heads 463,000 399,000 352,000 -2.9% 

 Per head Price $151 $97 $112 -8.4% Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data includes federal subsidies (EWG. Farm Subsi

TABLE 15 

Cattle and Calves Industry Trends: All Cattle Other than Beef and Dairy: San Joaquin Valley Region and Sta

1994-2004 ($2004) 

1994 1999 2004 94-99 

Region Aggregate Value $829,410,576 $854,776,429 $1,346,087,835 0.6%  Number of heads 1,534,709 1,740,622 2,251,367 2.6%  Per head Price $540 $491 $598 -1.9% State Totals Aggregate Value $1,311,021,059 $1,309,106,879 $1,917,232,892 0.0% 

Number of heads 3,958,854 4,290,000 4,680,000 1.6% 

 Per head Price $331 $305 $410 -1.6% Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report. Data includes federal subsidies (EWG. Farm Subsid
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TABLE 17 

Poultry and Eggs Industry Trends: San Joaquin Valley Region and State of California, 1994-200

1994 1999 2004 94-99 

Region Aggregate Value: Poultry $352,813,215 $359,030,294 $468,232,000 0.3% 

Pounds of poultry 641,431,000 700,211,319 791,409,389 1.8% 

 Poultry value per pound $0.55 $0.51 $0.59 -1.4% 

Aggregate Value: Eggs $162,733,051 $84,810,472 $132,460,000 -12.2% 

 Dozens 192,527,246 132,268,002 187,341,125 -7.2%  Eggs value per dozen $0.85 $0.64 $0.71 -5.4% State Aggregate Value: Poultry $391,348,691 $389,761,080 $689,303,956 -0.1%  Pounds of poultry* 1,131,000,000 Data unavailable Data unavailable  Poultry value per pound $0.35 ------- ------- 

Aggregate Value: Eggs $374,008,792 $265,620,390 $268,459,200 -6.6% Dozens 525,177,391 464,225,339 421,083,000 -2.4% 

 Eggs value per dozen $0.71 $0.57 $0.64 -4.3% Source: Applied Development Economics, based on State of California Agricultural Commissioners Annual Report and Annual Crop Report (various counties) (*Cal stopped 

of confidentiality) 
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 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 from 1992 to 2002. Data comes from Dun 

and Bradstreet. Dun and Bradstreet tracks a wide variety of business and financial indicators, 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 four-digit Standard Industrial Classification (SIC) level. Dun and Bradstreet track 

information on annual bases, allowing us to calculate a weighted average after tax 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 the top performing businesses 

within an industry in terms of net profit 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 profit ratio discussed above to industries affected by Rule 

4750, to generate an economic profile of affected industries in the region in terms of their respective numbers, 

employment, revenue, and net profits. 

Table 18 shows that there are approximately 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 economic 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 activity of an establishment that is primarily 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 dairy and wheat industry groups. 
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 For Proposed Re-Adoption of Rule 4570 

not purchase or sale of dairy cows. Table 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 employ an estimated 10,474 workers in the 

region, out of 18,144 who are employed throughout the state. It should be noted that official statistics from the 

California Employment Development Department (EDD) show that in all of California there are approximately 861 

cattle farms and, in the eight-county region, 235. However, the USDA Agricultural Census 2002 indicated that there 

were 17,380 and 5,860 cattle farms in the state and region respectively in the year 2002. Projecting to 2004 based on 

California EDD growth patterns between 2002 and 2004, we estimate that there are 16,212 cattle farms in the state and 

5,290 in the region. The discrepancy between the EDD and Agricultural Census data sets is important as it bears on the 

number of workers employed in the cattle industry. The discrepancy is largely attributable to the fact that the California 

EDD organizes its data by the primary activity an establishment is engaged in. So, if cattle farming is a secondary 

activity of a farm establishment that is primarily engaged in, say, wheat farming, 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 region, not 2,623 as indicated by 

the California EDD. In addition to employment, 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 and state. There are approximately 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. 
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TABLE 19 

Dairy Industry Profile: San Joaquin Valley Region and the State, 2004 

Dairies Emp (est) Aggregate Wages Dairy Cows (est) Production (CwT) Value Val

California 2,104 21,228 $532,980,310 1,735,800 358,445,714 $5,304,938,310 Region 1,500 16,805 $417,710,983 1,406,106 292,249,472 $4,321,127,613 Source: USDA, NASS Field Office, "California Agricultural Statistics 2004", California Agricultural Commissioners, and USDA ERS

TABLE 20 

Cattle Industry Profile: San Joaquin Valley Region and the State, 2004 

Cattle Operations Employment Aggregate Wages Nos. of heads Value Value per head 

California 16,212 18,144 $462,496,692 5,400,000 $2,461,336,892 $456 Region 5,290 10,474 $271,741,535 2,414,167 $1,461,529,000 $605 Source: California Agricultural Commissioners (number of cattle [head] and value), US Ag Census 2002 (cattle farms), Ca EDD (establishments, employment an(net profit) 

TABLE 21 

Swine Industry Profile: San Joaquin Valley Region and the State, 2004 

Swine Farms Employment Aggregate Wages Hogs sold Aggregate Value Value per head Est. Ne

California 1,485 4,137 $106,844,324 352,000 $39,293,974 $112 $Region 313 872 $22,526,459 337,983 $32,140,630 $95 Source: California Agricultural Commissioners (number of hogs [head] and value), US Ag Census 2002 (hog farms), Ca EDD (establishments, employment and wages), DnB (profit) and USDA ERS (net profits) 
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Appendix D: Socioeconomic 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 characteristics of affected industries against the compliance costs. The 

first part of this section discusses annual compliance costs. Section 6.2 discusses general business responses to 

compliance costs. Section 6.3 analyzes the socioeconomic impacts of Draft Rule 4750. 

6.1 compliance cost estimates 

Table 21 below identifies annual costs associated with Draft Rule 4570. The table summarizes costs estimates based on 

data provided by the San Joaquin Valley Unified Air Pollution Control District. For detailed discussion on the cost 

estimates, we direct your attention to a report issued by the 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 costs borne by affected dairy farms. The same methodology was used for beef 

feedlots, other cattle facilities, and swine facilities. 

First, we need to consider how many dairies farms and milk 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. And, of the 430 dairy farms, 233 

are out of compliance and will have to implement 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 mitigation 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 included some cost activities that are attributable only to milk 

cows and not to support cows. This was taken into account when we determine that 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 compliance 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 and, where practical, shift from lower-value to higher-value product and or crop. Affected 

sources may also seek to renew efforts to increase productivity and reduce costs elsewhere in their operation in order to 

recoup the regulatory costs and maintain profit levels. It is important 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 ability 

to pass on costs to the consumer. As prices 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. 
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Appendix D: Socioeconomic 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 net profits of affected industries against anticipated costs 

associated with implementation of the draft rule. The net profit 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 these 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 District staff and stakeholders. 

Table 23 below compares the total annual compliance costs discussed 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 Development Economics, based on California Agricultural Commissioners, US Ag Census 2002, Ca EDD, DnB and ESDA ERS 

Both beef cattle operators and other cattle 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 costs out of $191 million in estimated annual profits. This impact is below the ten percent 

threshold of significance employed for the purposes of evaluating the impact of air quality 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 buyer 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 input-output model, the consultant estimated the multiplier 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix D: Socioeconomic 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 threshold of significance, looking particularly at two measures 

– employment and industry output. These 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 multiplier descriptions are 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 associated with reductions in 

household purchases tied to direct and indirect employment losses in the 

region. These induced impacts most typically occur in retail and other localserving industry categories such as personal services, education, and health 

care. 

Table 24 shows the direct, indirect and induced 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 industry, there will be an indirect 

loss of 17 additional workers in businesses with whom affected 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 number 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 number 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 NA 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix D: Socioeconomic 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 requires that the socioeconomic 

analysis assess whether small businesses are disproportionately affected by air quality rules. This section begins by 

briefly summarizing how the state government defines small businesses for the purposes of qualifying certain businesses 

for various programs. This section concludes with a discussion as to whether the affected industries include small 

businesses and assesses whether 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 manner3. To be eligible for small business 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 affiliates, be either: 

• A business with 100 or fewer employees, and an average gross 

receipts of $10 million or less over the previous tax years, or 

• A manufacturer with 100 or fewer employees. 

Based on conversation with District staff, who know the dairy and cattle companies impacted by the rule, we conclude 

that Rule 4570 does not disproportionately impact small business sources. 

 

3

 State of California. Department of General Services. “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 Report submitted with SIP June 18, 2009 

Appendix D: Socioeconomic 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 good should change from one year to the next, if it is to 

holds its value in inflation-adjusted terms. Most importantly, this chart allows us to compare revenue data that was 

issued in 2004 against data that was issued in previous years, particularly 1994 and 1999. 

FIGURE A 

 United States Bureau of Labor Statistics: 

Consumer Price Index (US Urban Wages), 1994-2004 

To maintain its inflation-adjusted value 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 value of something is $1.00 is compared against 2004 data that indicates the value of 

the same good is, say, $1.55, the correct comparison is not 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 inflation run the risk of conveying less than accurate descriptions of economic trends, 

oftentimes resulting in an overstatement of the magnitude of change that occurred between two points in time. 

While accounting for inflation for analytical purposes is fairly straightforward, there are a number of other worthy 

considerations. It should be noted that businesses can not simply raise prices (change price tags as it were) to keep up 

with inflation. Upward shifts in prices from one year to the next could result in disproportionate reduction 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 price, 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 Report submitted with SIP June 18, 2009 

Appendix D: Socioeconomic 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 meat may trigger shifts in consumption away from meat toward 

poultry, which typically costs less. 4

 

4

 While many businesses cannot adjust their prices to account for inflation for reasons related to market share and 

profitability, this is not entirely the case for all businesses and 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. Companies that sell at prices similar to the previous year can 

mitigate inflation risks and generate profit through improved 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 production 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix D: Socioeconomic Analysis for Rule 4570 June 15, 2006

Applied Development Economics C-143 Final Staff Report with Appendices 

 For Proposed Re-Adoption of Rule 4570 

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Appendix C: 2006 Final Staff Report 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 (CONFINED ANIMAL FACILITIES) 

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

Appendix C: 2006 Final Staff Report 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 Safety Code, prior to adopting, 

amending of a rule or regulation, the District is required to perform a written analysis 

that identifies and compares the air pollution control elements of Rule 4570 with the 

corresponding elements of existing or proposed District and EPA regulations and 

guidelines that apply to confined animal facilities. The elements that were analyzed are 

mitigation measures, monitoring and testing, and recordkeeping and reporting 

requirements. Staff found that facilities could comply with Rule 4570 and all existing 

District Rules. Furthermore, staff found that none of the requirements 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 facilities. Emission sources subject to 

proposed Rule 4570 are subject to the following rules: 

• 3190 (Conservation Management Practice Fee)- This rule applies fees to recover 

costs for the District's Conservation Management 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 exempt from Rule 4550. 

• Dairy and cattle operations- The decreased moisture that reduces VOC 

emissions can increase PM emissions. Since Rule 4550 is intended to 

reduce PM emissions while proposed Rule 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 requirements while choosing options that reduce moisture; 

choosing options that increase moisture; or choosing options that do not 

affect moisture. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 Elimination System permit. 

Nothing in Rule 4570 would preclude this. 

2. EPA “Control Techniques Guideline (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 records for at least five years. 

C. California Rules, Regulations, and Policies 

1. CCR Title 27 §13260 & 13263 

These sections require any person discharging or proposing to discharge wastes that 

could affect the quality of surface or groundwater to notify the Regional Water Quality 

Board. The person shall implement state and federal water quality control policies as 

well as the Basin Plan for the applicable area. Rule 4550 provides sufficient options 

such that no requirements of the Regional Water Quality 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 the 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 entering surface water; requirements 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 inconsistent 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 Report 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 corrals 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 floors, curbs, and gutters of the milking barn be constructed of 

concrete or other acceptable material and sloped 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 roof 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 Draft Waste Discharge Requirements 

The Regional Water Quality Board is drafting waste discharge requirements (WDR) for 

dairies. Since these will not be finalized prior to Rule 4570 adoption, staff can 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 requirements. The 

differences between the rules are due to the different goals, relevant science available, 

and jurisdictions of the agencies. The significant difference between the two proposed 

rules are: 

• Definition of a confined animal facility 

• WDR: facilities feeding by a method other than grazing at any time. 

• Rule 4570: facilities feed by a method other than grazing for at least 45 days. 

(Staff included the 45 day threshold because 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 milkers are subject to the rule (Staff used 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 determined by the ARB since the emission 

factor data for air, unlike for water, is not well established; thus, staff does not 

believe they can make the determinations necessary to go below the ARB's 

large CAF definition.) 

• Land application of solid manure 

• WDR: facilities shall land incorporate within forty-eight (48) hours. 

• Rule 4570: facilities shall land incorporate within seventy-two (72) hours. 

(Staff used seventy-two (2) hours to acknowledge 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 manure 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) hours 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 would be the minimal reasonable time period, staff 

incorporated this time period into Rule 4570.) 

It is important to mention that in cases 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 Report 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 

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

Appendix F: Ammonia Reduction Analysis 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 (CONFINED ANIMAL FACILITIES) 

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

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

Appendix F: Ammonia Reduction Analysis 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 require operators of Large Confined 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 NH3 will be reduced by Rule 4570 requirements. 

Emissions reductions are summarized in Table 1. Ammonia reductions were 

calculated according to the methodology explained 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 NH3 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 NH3

Emissions (tpd) 

NH3 Emissions from 

Large CAFs (tpd) 

NH3

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 0 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix F: Ammonia Reduction Analysis 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 decomposition or moisture in organic material 

reduce both VOC and ammonia reductions most of the VOC mitigation measures also 

reduce ammonia. 

Staff assumed that the percentages of the total VOC emissions attributable to each 

emission source are identical to the percent of total NH3 emissions attributable to each 

emission source. Since there is an assumed relationship between ammonia and VOC 

emissions, the percentages from Table 2: Summary of Emission 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 NH3 Emissions)= 

NH3 Emissions from Emission Unit. 

Staff then made the following 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 Analysis" in State of the 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 equivalent to the percent of NH3 emitted by each type of 

dairy animal compared to the NH3 emitted by a milk cow. The calculations are 

below: 

• NH3 Emissions Non-Milker = VOC Emissions from Non-Milker ÷VOC Emissions from 

Milker (21 lbs/hd/yr for freestall dairy) x NH3 Emissions from Milker (74 lbs/hd/yr). 

• Therefore: 

• NH3 Dry Cow = 11.9 ÷ 21 x 74 = 40.93 lbs/hd/yr 

• NH3 Heifer 15-24 Mo. = 8.3 ÷ 21 x 74 = 29.25 lbs/hd/yr 

• NH3 Heifer 7-14 Mo = 7.2 ÷ 21 x 74 = 25.37 lbs/hd/yr 

• NH3 Heifer 4-6 Mo = 6.6 ÷ 21 x 74 = 23.26 lbs/hd/yr

• NH3 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 Report submitted with SIP June 18, 2009 

Appendix F: Ammonia Reduction Analysis 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 determination of the emission factor, however, Dr. CE 

Schmidt in his "Assessment of Reactive Organic Gases and Amines from a Northern California Dairy 

Using the USEPA Surface Emission Isolation Flux Chamber" presented to ARB Jan. 26, 2005 quantified 

these. Additionally, this assumes the worst-case scenario 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, the District's ammonia emission factor for 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 dry cow numbers in the San Joaquin Valley, 

from a California Department of Food and Ag (CDFA) report entitled “California 

Agricultural Statistics 2004”. These numbers only include milking 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 submitted to the District. Based on those applications the 

following ratios were developed. These ratios 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- Non-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 Report submitted with SIP June 18, 2009 

Appendix F: Ammonia Reduction Analysis 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 calculations 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 estimate 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 feeding according to NRC, guidelines affect all 

animals and emission sources at the facility. Other control measures, such as using a 

phototrophic lagoon, only affects one emission source—the lagoon. 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 SJVAB
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix F: Ammonia Reduction Analysis 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 reductions. In Section D, staff explained the calculations in 

more detail. In general, the calculations are: 

Total NH3 = Animals Affected x Emission Factor 

Reductions (Red) = Animals Affected (An. Af.) x Emission Factor (EF) for animals in 

areas affected (Areas) x (1-Percent Previously Controlled NH3 (Prev. Cont)) x Control 

Efficiency of Control Measure (CE) 

Option 1: Feed Adjustment

This measure assumes that the owner/operator will feed all 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 emissions at the facility. 

SCAQMD Tetra Tech Report showed approximately 28% reduction in ammonia 

emissions from reducing the protein content in feed by 4%. Studies on swine, 

referenced in the draft staff report, showed similar percentages 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 Reduces Odor Production in Finishing Beef Cattle Manure 

Without Sacrificing Performance" by S.L. Archibeque et al use 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, approximately 71% of the facilities have freestalls. 

Additionally, few calves are housed in freestalls. Therefore, staff assumed 71% of the 

animals other than calves would be affected by this control. Since the cleaning only 

applies to waste (feed and manure) in the animal housing, the emission factor from 

Table 3 for Cow Housing-Not Enteric was utilized. 

Staff assumed that the control efficiency for ammonia is approximately the same as the 

control efficiency of VOCs. Since the preliminary BACT showed a 47.7% VOC control 

efficiency for increased cleaning of freestalls, staff assumed that, together, all activities 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix F: Ammonia Reduction Analysis 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 efficiency for the low estimate. The SCAQMD 

Tetra Tech Report showed 50% reductions, therefore 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% (control 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% (control 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 reduction 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% VOC control efficiency for application of 

lime, one of the methods for minimizing moisture 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 utilized 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% (control 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% (control efficiency)= 2.66 lb/hd/yr 

This is out of an emission factor of 74 lb/hd/yr. 

The low percent reduction 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 Cleaning
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix F: Ammonia Reduction Analysis 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%, staff assumes that it reduces 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 remaining after Option 3) x 50% (control 

efficiency)= 1.72 lb/hd/yr 

This is out of an emission factor of 74 lb/hd/yr. 

The low percent reduction 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 included in the baseline; therefore, no additional 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 reduced lagoon loading with VOC emissions and 

promotion of phototrophic conditions, 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) found 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 Alaska: Biological and Social Challenges in 

Wildlife Management by the National Research Council published by the National 

Academy Press in 1997, in addition to other publications show a correlation 

between the quantity of food in a biosystem and the quantity of organisms. 

Therefore, although there is more nitrogen in a dairy lagoon than a swine lagoon, 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix F: Ammonia Reduction Analysis for Rule 4570 June 15, 2006 

 C-158 Final Staff Report with Appendices 

 For Proposed Re-Adoption of Rule 4570 

staff would assume the population of microorganisms consuming the nitrogen 

would increase to match the supply. Therefore the control efficiency between a 

swine and dairy lagoon would be similar—80% to 90% 

Option 6 Low Reductions = 9.25 lb/hd/yr x 72% (emissions remaining after 

implementing Option 1) x 80% (control 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% (control efficiency)= 4.50 lb/hd/yr 

This is out of an emission factor of 74 lb/hd/yr. 

The low percent reduction 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 staff assumed that use of control 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% (control 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% (control efficiency)= 4.61 lb/hd/yr 

This is out of an emission factor of 74 lb/hd/yr. 

The low percent reduction 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/yr 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix F: Ammonia Reduction Analysis 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 emissions at each emission unit, as shown below. 

*These emissions were not quantified in the initial determination of the emission factor, 

however, Dr. CE Schmidt in his "Assessment of Reactive Organic Gases and Amines 

from a Northern California Dairy Using the USEPA Surface Emission Isolation Flux 

Chamber" presented to ARB Jan. 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 emission 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 Report submitted with SIP June 18, 2009 

Appendix F: Ammonia Reduction Analysis 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 affects one emission source—the lagoon. In Section D staff 

explained the calculations in more detail. In general the calculations are: 

Total NH3 = Animals Affected x Emission Factor 

Reductions (Red)= Animals Affected (An. Af.) x Emission Factor (EF) for animals in 

areas affected (Areas) x (1-Percent Previously Controled NH3

(Prev. Cont)) x Control Efficiency of Control Measure (CE) 

Staff assumed that the control efficiencies for each practice for the dairy were the 

same for beef. 

Option 1: Feed Adjustment

This measure assumes that the owner/operator will feed all 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 emissions at the facility. 

SCAQMD Tetra Tech Report showed approximately 28% reduction in ammonia 

emissions from reducing the protein content in feed by 4%. Studies on swine, 

referenced in the draft staff report, showed similar percentages 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 Reduces Odor Production in Finishing Beef Cattle Manure 

Without Sacrificing Performance" by S.L. Archibeque et al use 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% VOC control efficiency for application of 

lime, one of the methods for minimizing moisture in corrals. Staff assumed that, 

together, all activities to minimize moisture achieve 50% control efficiency for the low 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix F: Ammonia Reduction Analysis 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 utilized 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 reduction 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%, staff assumes that it reduces 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 reduction 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 Report submitted with SIP June 18, 2009 

Appendix F: Ammonia Reduction Analysis 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 staff assumed that use of control 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 reduction 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 are being raised for replacement animals on 

dairies, as veal, or as stock for beef feedlots. 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 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Appendix F: Ammonia Reduction Analysis 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 efficiency 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/yr 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 (CONFINED ANIMAL FACILITIES) 

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

Appendix C: 2006 Final Staff Report 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 Pollution 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 confined animal facility located within the boundaries of the 

San Joaquin Valley Unified Air Pollution Control District (see Exhibit 1, Map of 

District boundaries). 

 

5. Project Sponsor’s Name and Address: 

 

San Joaquin Valley Unified Air 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 emissions are temperature dependent with the 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 summer when the SJVUAPCD experiences the 

largest number of exceedances of the Federal health based ozone standards. 

Rule 4570 fulfills a control measure commitment in the 2004 Extreme Ozone Attainment 

Demonstration Plan, and meets the requirements of State Senate Bill (SB) 700, and the 

Reasonably Available Control Technology (RACT) provisions of the Federal Clean Air 

Act (CAA). Under SB 700, Confined 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 reduce their VOC emissions. CAA section 

182(b)(2) requires existing facilities that exceed the federal major source thresholds to 

implement Reasonably Available Control Technology (RACT). The RACT threshold is 

currently 10 tons/year in the San Joaquin Valley. 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 estimates 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 rule. New CAFs that 

exceed 1⁄2 of the District’s major source threshold (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. Therefore, these large new sources will meet 

or exceed Rule 4570 by implementing controls required during the District’s new source 

review permitting process. 

Draft Rule 4570 incorporates a cafeteria-based approach that would require each large 

CAFs to reduce their baseline uncontrolled emissions by approximately 30% annually. 

This would equate to annual emission reductions 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 emission factor for each type of animal by the 

number of that type of animal on the facility. Operators would have the flexibility to 

comply with the Rule using any combination of the following emission reduction 

measures: 

A. Feed and silage management practices such as: using feed formulation practices; 

increased feed removal and cleaning practices; feed and silage storage practices; 

and others. 

B. Increased cleaning of the milk parlor, where applicable. 

C. Increased cleaning frequency in various 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 Report 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 manure and separated solids such as: covering 

dry manure piles, removing manure from the 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 application of animal waste such as: land 

incorporate all solid manure within seventy-two (72) hours; only apply waste that 

has been anaerobically treated; minimize moisture content of solid manure that is 

land applied; and others. Design lagoons and load lagoons according to National 

Resource Conservation Service (NRCS) guidelines. 

I. House animals in enclosures that are vented to control devices with VOC control 

efficiencies of at least 80%. 

Please refer to Draft Rule 4570 and draft staff report which are available 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 Report 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 Boundaries 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 effective strategy for 

reducing their emissions. Given the cost differential between installing VOC controls on 

lagoons or enclosing their housing and pursuing emissions reductions elsewhere, it is 

unlikely that the industry will install VOC controls on lagoons or enclose housing. The 

most likely approach for complying with Rule 4570 is operators will mitigate emissions 

by feeding according to NRC guidelines; increased 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 phototrophic lagoons; and rapid land incorporation of 

manure. 

7. Other Agencies Whose Approvals Is Required and Permits Needed: 

 

Modified and new dairies may require permits from the Regional Water Quality Control 

Board, California Integrated Waste Management 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 with Existing Zones and Plans: 

 

Adoption of this Rule will not affect any land use zones or plans. 

 

9. Name of Person Who Prepared Initial Study: 

 

Ms. Lucinda Roth 

Air Quality Specialist 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 FACTORS POTENTIALLY AFFECTED

The environmental factors checked below would 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 Significance 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 described on attached sheets. An 

ENVIRONMENTAL IMPACT REPORT is required, 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 significant effects (a) have been analyzed 

adequately in an earlier EIR or NEGATIVE 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 imposed upon the proposed project, nothing further is 

required. 

Signature: Date: 

Printed Name: Lucinda Roth Title: Air Quality Specialist 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 checklist 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 the 

California 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? 

 X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 status 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 interruption, or other 

means? 

 X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 native 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. 

 X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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? 

 X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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)? 

 X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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? 

 X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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? 

 X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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? 

 

X 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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? X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 provider 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? 

 X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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? 

 X
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 aesthetic impacts from Draft Rule 4570 

(Confined Animal Facilities) because potentially affected sites are already 

developed as confined animal facilities and any aesthetic impact would already 

exist. New sites subject to the provisions of Draft Rule 4570 would incorporate 

any necessary equipment into the design to minimize potential aesthetic impacts 

in accordance with local agency standards. 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 glare, which would have a significant adverse 

effect on day or nighttime views in potentially 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 site chooses to install VOC control systems 

on their confined animal facility, the systems 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 option to determine specifically where to 

install the VOC control systems. Options are also available for the affected site 

owner/operators to choose VOC control options 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 instead of a management practice will be a decision resting 

solely upon the potentially affected site owners/operators. 

Draft Rule 4570 will not result in a substantive conversion of prime or unique 

farmland to non-agricultural use. As noted above, installing a VOC control system 

on a site devoted to agriculturally productive land will be a decision resting solely 

upon the potentially affected site owners/operators and in any case would require 

very small amounts of land. Since the dairy is an agricultural use, there will be no 

impact or conflict with existing zoning for 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 nonattainment area for the health-based air 

quality standards established by the federal Clean Air Act. The SJVAB is also classified 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 for the California ozone standard and nonattainment for the 

California PM10 standard. VOC is a precursor 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 emissions control device or management practice will 

result in a positive air quality benefit. 

Draft Rule 4570 will not violate any air quality 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 significant adverse effect 

on the habitat of sensitive species, riparian 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 local policies or ordinances protecting 

biological resources or conflict with any Habitat Conservation Plan. No additional 

significant adverse impacts to biological resources are expected to result from Draft 

Rule 4570 because it is expected to affect only agricultural/commercial areas where 

biological resources are already disturbed. 

V. Cultural Resources 

Effects from implementing Draft Rule 4570 will occur at existing potentially 

affected facilities generally located in agricultural/commercial areas. As a result, 

significant adverse impacts on cultural resources 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 constructed in the future will go through a 

local agency approval and in most counties an environmental review process 

where screening for cultural resources would be addressed. 

VI. Geology and Soils 

Draft Rule 4570 provides an option for some owners/operators to install VOC controls 

on their facilities. Installation of VOC controls on existing sources could result in 

modifications to the existing facilities to accommodate additional control equipment. 

Modification of an existing site is expected to constitute the most extreme compliance 

strategy. Draft Rule 4570 contains a provision 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 siltation 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 management practice; therefore no new impacts are 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix C: 2006 Final Staff Report 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 provisions 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 emissions control systems. 

These systems would most likely consist of ductwork used to collect emissions and 

transport them to an emissions control device. These are established technologies and 

employed in other industries. Owners/Operators must comply with federal, state, and 

local safety and environmental regulations. Existing regulations are considered 

adequate to minimize significant worker exposure 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 sites and smaller areas for smaller facilities. 

The potentially affected site retains the option of where it will specifically install the VOC 

control systems, thus selecting a site within the 100-year flood zone will be a decision 

by the site owners/operators and the local agency issuing a building permit for 

construction of the equipment and must comply with the regulations of the Regional 

Water Quality Control Board. Use of additional water for flushing or control devices on 

lagoons are a few of many control options available to site 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 would not result in significant increases in 

water use at the facilities. 

Draft Rule 4570 will not result in a significant adverse impact to hydrology nor 

water quality will be significantly adversely impacted by the proposed project 

IX. Land Use and Planning 

There are no provisions in Draft Rule 4570 that would affect land use plans, policies, or 

regulations. It is also expected that Draft Rule 4570 will not affect infrastructure 

development or require changes to existing zone designations because the draft 

provisions primarily regulate existing facilities. Local governments determine land use 

and other planning considerations, and no land use or planning requirements will be 

altered. Therefore, present or planned land uses in the region 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 Report 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. Future 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 land use authority. 

XI. Noise 

A facility selecting to implement the retrofitting 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 increase 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 equipment is expected to be negligible. Noise levels will 

remain below significant levels and no significant adverse impacts are anticipated. 

XII. Population and Housing 

There are no provisions in Draft Rule 4570 that would result in the creation of any 

industry that would significantly affect population growth, or directly or indirectly 

induce significant construction of single- or multiple-family 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 device or system that would result in a substantial change 

or significant adverse impact on existing demands for public services. Draft Rule 

4570 will not result in significant adverse 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 resources 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 existing agricultural/commercial areas where 

deliveries and commodity hauling are routine. As a result Draft Rule 4570 will not cause 
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a substantial increase in the number of transport trips to confined animal facilities 

delivering raw materials or operational supplies. Future sites will be evaluated for 

Transportation/Traffic impacts as part of the review process for new developments 

regularly undertaken by agencies 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 treatment facilities be 

built. Construction of new storm water 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 significantly as a result of meeting the 

requirements of the rule. 

Controlling VOC emissions from CAFs could require increased flushing, however the 

water is typically reused, therefore no significant net increase in water use is expected. 

Draft Rule 4570 does not mandates control of waste disposal systems, nor 

impose control system designs. Operational practices are discretionary and are 

not mandated by the rule. Therefore, implementing the provisions of Draft Rule 

4570 are not expected to result in significant adverse impacts on existing water 

resources or the need to explore new water resources. 

Facilities selecting to install VOC control systems may be required to comply with 

requirements of the Regional Water Quality Control Board (RWQCB). Site by site 

evaluations will determine if potentially affected sites must receive approvals from the 

RWQCB in the form of General Stormwater Permits for Construction and Industrial 

Activities, Waste Discharge Permit, preparation 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 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. 

This project does not have the potential to achieve short-term, to the disadvantage of 

long-term, environmental goals. Neither does this project have impacts, which are 

individually limited, but cumulatively considerable. This project will have no potential 

environmental effects that will cause substantial adverse effects on human beings, 

either directly or indirectly. 
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Based upon consideration of the information provided in the comments to the 

Environmental Checklist and other analyses performed for this project, it does not have 

the potential to degrade the quality of the environment or to interfere with either shortterm or long-term environmental goals. There will not be any significant cumulative 

impacts. Finally, the project will not cause any direct or indirect substantial adverse 

effects on human beings. 
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Appendix H: Recent Dairy Emission Research June 15, 2006 

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APPENDIX H 

RECENT DAIRY EMISSIONS RESEARCH FOR 

PROPOSED RULE 4570 (CONFINED ANIMAL FACILITIES)

June 15, 2006 
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RECENT DAIRY EMISSION RESEARCH 

I. Latest Research Supports Comprehensive Strategies for Dairy Emissions 

Reductions 

New research studies carried out under the direction of California air quality regulators 

have confirmed that dairies are complex sources of air emissions. This research 

demonstrates significant, landmark progress in both understanding the 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 state, 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 nature of the dairy emissions 

themselves and the most effective ways to reduce those emissions: 

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

from cows housed in environmental chambers to evaluate emissions directly 

from cows and their fresh manure; 

• A study at two operating dairies in the San Joaquin Valley, led by Dr. Chuck 

Schmidt, in which measurements were made at many locations on and around 

the dairy facilities including the corrals and turnouts, bedding areas, lagoons, 

feed storage areas, flush lanes, and bunker feed; and 

• A study by Dr. Schmidt to validate the 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, varying 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 characteristics. Other key findings include: 
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• Cattle feed stored on California dairies may 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 are 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 known 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 industry 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 expanding dairy operations have been required 

since 2004 to adopt stringent emissions reductions measures (known as Best 

Available Control Technology or BACT) before receiving a construction permit. 

• Existing dairies in the San Joaquin Valley dairies are required to adopt measures 

known as Best Available Retrofit Control Technology (BARCT); these will be 

covered under new regulations collectively known as Rule 4570. 

Both actions are required under Senate Bill 700 (Florez), a new state law that mandates 

air pollution permits for large farms and livestock facilities. For existing dairies in the 

San Joaquin Valley, proposed Rule 4570 would require dairy operators to adopt at least 

19 separate management practices 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 emissions from dairies. Additional work is 

needed to allow a comprehensive update to the interim emission factors currently being 

used for dairies. To this end, longer-term research is being undertaken. At the January 

hearing of the Air Resources Board, the Board approved a project with UC Davis to 

begin development of a process-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, best 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 of 
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emissions from land application of manure, solid manure handling and other areas of 

dairies. 

Later in 2006, there are tentative plans to hold a research symposium to discuss recent 

dairy research, ongoing efforts, and future plans. 
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APPENDIX I 

ALTERNATIVE MITIGATION MEASURE DESCRIPTION 

PROPOSED RULE 4570 (CONFINED ANIMAL FACILITIES)

June 15, 2006 
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ALTERNATE Mitigation Measures Under Rule 4570 

“a mitigation measure that is determined 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 that owners/operators could 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 control 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 effective as other rule options. 

• Purpose of policy is to ensure that each proposed alternate technology is fully 

evaluated and that evaluation is fully documented. 

• Policy is consistent with existing ATC application process. 

• Substitute measures cannot be implemented until fully approved. 

• Applicants are required to submit specific detailed information in writing. 

• Policy includes a detailed evaluation procedure 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 review as required by the rule. Any 

comments must be addressed to EPA and ARB satisfaction.