ATTACHMENT G 

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

Draft Final Staff Report 

Proposed Rule 1127 – Emission Reductions From Livestock Waste 

June 4, 2004August 6, 2004

Deputy Executive Officer 

Planning, Rule Development and Area Sources 

Elaine Chang, DrPH 

Assistant Deputy Executive Officer 

Planning, Rule Development and Area Sources 

Laki T. Tisopulos, Ph.D., P.E. 

Authors: Julia C. Lester, Ph.D. – Program Supervisor

 Mary Woods, Ph.D. – Air Quality Specialist 

Reviewed By: Barbara Baird - District Counsel 

 Frances Keeler - Senior Deputy District Counsel 

 

Contributions: Mike Garibay – Senior Air Quality Engineer 

 Michael Krause – Air Quality Specialist 

 Patricia Kwon - Air Quality Specialist 

 Kathy Stevens - Air Quality Specialist 

 Charles Tupac - Senior Air Quality Engineer 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD

CHAIR: WILLIAM A. BURKE, Ed.D. 

 Speaker of the Assembly Appointee 

 

VICE CHAIR: S. ROY WILSON, Ed.D. 

 Supervisor, Fourth District 

 Riverside County Representative 

MEMBERS: 

MICHAEL D. ANTONOVICH 

Supervisor, Fifth District 

Los Angeles County Representative 

JAN PERRY 

Councilmember, City of Los Angeles 

Cities Representative, Los Angeles County, Western Region 

JANE W. CARNEY 

Senate Rules Committee Appointee 

WILLIAM CRAYCRAFT 

Councilmember, City of Mission Viejo 

Cities Representative, Orange County 

BEATRICE LAPISTO-KIRTLEY 

Councilmember, City of Bradbury 

Cities Representative, Los Angeles County, Eastern Region 

RONALD O. LOVERIDGE 

Mayor, City of Riverside 

Cities Representative, Riverside County 

BILL POSTMUS 

Supervisor, First District 

San Bernardino County Representative 

JAMES W. SILVA 

Supervisor, Second District 

Orange County Representative 

CYNTHIA VERDUGO-PERALTA 

Governor's Appointee 

DENNIS YATES 

Councilmember, City of Chino 

Cities Representative, San Bernardino County 

EXECUTIVE OFFICER: 

BARRY R. WALLERSTEIN, D.Env. 
Table of Contents 

PR 1127 i June 2004 August 2004

TABLE OF CONTENTS 

Executive Summary ................................................................................................ 1 

Background and Legal Authority .......................................................................... 2 

Air Quality Regulations............................................................................... 2 

Water Quality Regulations ....................................................................... 4 

Industry Profile ........................................................................................................ 6

Emissions Inventory ............................................................................................... 12

Proposed Control Technologies and Practices ..................................................... 17

Summary of Proposed Rule Requirements ......................................................... 21

Cost Effectiveness ................................................................................................... 24 

Environmental Assessment..................................................................................... 29 

Socioeconomic Assessment ..................................................................................... 29 

Outreach and Public Comments ........................................................................... 29 

Draft Findings and Comparative Analysis...................................................... 3741

List of Figures and Tables 

Figure 1 –Santa Ana and San Jacinto Watershed Locations (SAWPA) ........ 5

Figure 2 – Distribution of Poultry and Dairy Operations in the Basin ............. 8

Figure 3-1 – Cows at the Feed Lane....................................................................... 9 

Figure 3-2 – Cows at the Watering Trough in the Corral ................................... 10 

Figure 4 – Typical South Coast Dairy Production Facility.................................. 11 

Table 1 –- Summary of Manure Handling In SARWQCB Region .................... 14

Table 2 –- Total Control Effectiveness of Manure Practices............................... 16

Table 3 –- Manure Disposal For Future Years ..................................................... 16

Table 4 –- Emission Estimates (tons/day) Without PR1127 ................................ 17 

Table 5 –- Total Control Effectiveness of Manure Practices with PR1127 ........ 19

Table 6 –- Manure Disposal For Future Years with PR1127 .............................. 19

Table 7 –- Emission Estimates (tons/day) With PR1127...................................... 20

Table 8 –- Emission Estimates (tons/day) Alone................................................... 20

Table 9 – Comparison of Remaining Emission after PR1127 with 

 WST-01 Target Levels (tons/day).......................................................... 20 
Table of Contents 

PR 1127 ii June 2004 August 2004

Table 10 – Near Term Local Dairy Relocations ................................................... 21

Table 11 – 2010 Alternate Future Emissions With Pr1127 (tons/day)................ 21

Table 12 – Cost of Manure Disposal Options (adjusted to tipping-fee basis) .... 25

Table 13 – PR1127 Cost Effectiveness ................................................................... 26 

Table 14 – Summary of Costs and Assumptions................................................... 27 

Table 15 – Absolute Cost Effectiveness.................................................................. 27

Table 16 – Incremental Cost Effectiveness Compared to Fabric In-Vessel ....... 27

APPENDICES 

Appendix A: Control Options

Appendix B: Draft PR1127 (dated June 4, 2004)
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 1 June 2004 August 2004

EXECUTIVE SUMMARY 

The purpose of Proposed Rule (PR) 1127 is to reduce ammonia, volatile organic compounds 

(VOC) and particulate matter under 10 microns (PM10) from dairies. PR1127 is designed to 

implement the Air Quality Management Plan (AQMP) control measure WST-01 and 

establish BACM requirements for dairies called for by SB700. 

The South Coast Air Quality Management District (AQMD) exceeds state and federal 

ambient air quality standards for PM10 (fine particulate matter less than 10 microns in 

diameter) and ozone. Since 1994, the AQMD prepared and adopted AQMPs that have 

included a control measure (WST-01) to reduce ammonia, VOCs, and PM10 from livestock 

waste. The control measure was updated in the 1997 AQMP, the 1999 AQMP/Ozone 

AQMP revision and the 2003 AQMP State Implementation Plan (SIP). The control measure 

calls for a 50% reduction in ammonia and a 30% reduction in VOC emissions from 1997 

AQMP base year (1993) levels by 2006. California SB 700, adopted in September 2003, 

removes the exemption for agricultural sources from regulatory requirements and requires 

that for each serious PM10 non-attainment area, districts must adopt best available control 

measures (BACM) for agricultural stationary sources of air pollution by July 1, 2005, with 

implementation no later than July 1, 2006. 

The local dairy industry is unique in many ways. Almost all dairies use a dry-lot corral 

system, as opposed to the more prevalent flushed lane system used elsewhere in California 

and the nation. Increasing urbanization is inducing many farmers to relocate; the same 

process occurred in the 1970s when dairies moved from Los Angeles County to San 

Bernardino and Riverside counties. By 2015 or 2020, the total number of dairy cows will 

probably reduce by half from mid-1990 levels. Reduced cattle populations will reduce dairy 

manure emissions. In addition, stricter water quality regulations adopted in 1999 have 

changed the dairies’ manure handling and land spreading operations. Some of the water 

regulations also reduce manure emissions. 

As noted in the 2003 AQMP control measure WST-01, the 1997 AQMP set a “target” level 

of remaining emissions from dairy operations; 50% ammonia reductions and 30% VOC 

reductions from the 1993 base year emissions by 2006. Adjusted for the latest emission 

factors and emission methodologies, the 2003 AQMP baseline emissions for VOCs, 

ammonia, and PM10 from dairy manure are approximately 10.0, 25.9, and 1.3 tons per day, 

respectively, in 1993. In the absence of PR1127 but accounting for emission reductions from 

dairy relocations and water quality regulations enacted in 1999, the 2010 dairy manure 

emissions are estimated to be 4.5 tons per day VOC, 12.7 tons per day ammonia, and 0.8 tons 

per day PM10. 

Facilities affected by the proposed rule include agricultural operations or facilities that are 

directly related to raising cows and/or producing milk from cows for the purpose of making a 

profit or for a livelihood, i.e., dairy, heifer and calf farms. PR1127 will also affect manure 

processing operations, such as composting facilities and anaerobic digesters. PR1127 would 

require Best Management Practices (BMP’s) on dairies, including dust prevention and more 

frequent manure removal. PR1127 would establish requirements for alternative manure 

composting operations that allow manure composting in in-vessel systems that may not meet 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 2 June 2004 August 2004

all the requirements of Rule 1133.2 for co-composting operations. It is proposed that farms 

that have fewer than 50 cows would be exempt from PR 1127 requirements. 

With the implementation of PR1127 and accounting for the impact of dairy relocation and 

water quality regulations, remaining emissions in 2006 are 10.7 tpd ammonia and 3.8 tpd 

VOC; the 2003 AQMP target levels are 13.0 tpd ammonia and 6.7 tpd VOC. Thus, the 2003 

AQMP control requirements of WST-01 will be exceeded with the implementation of 

PR1127. SB700 BACM requirements for dairy and related operations will be met through 

implementation of existing Rule 1186, “PM10 Emissions from Paved and Unpaved Roads, 

and Livestock Operations,” adopted in 1997 and amended in 2004, and adoption and 

implementation of PR1127. 

Remaining emissions in 2010 after the implementation of PR1127 are estimated to be 3.3 

tons per day VOC, 9.4 tons per day ammonia, and 0.8 tons per day PM10. Reductions from 

the impact of PR1127 alone (separate from reductions due to dairy relocation and the air 

quality benefit of water quality regulations) are 3.3 tpd ammonia and 1.2 tpd VOC in 2010. 

The cost effectiveness for PR 1127 is $5,800.per ton of VOC reduced and $2,070 per ton of 

NH3 reduced and $2,070 per combined ton of NH3 and VOC reduced. 

 BACKGROUND AND LEGAL AUTHORITY 

The AQMD is the local government agency responsible for air quality assessment and 

improvement in Orange county, the non-desert portions of Los Angeles and San Bernardino 

counties, and most of Riverside county. AQMD jurisdictional boundaries include all of the 

Basin and portions of the Salton Sea Air Basin (SSAB). AQMD air monitoring indicates that 

these air basins exceed State and federal health-based air quality standards for PM10 and 

ozone. Accordingly, the U.S. EPA has designated both the SCAB and the SSAB as serious 

non-attainment areas for PM10 and extreme non-attainment for ozone. Under the federal 

Clean Air Act, the AQMD is required to attain the PM10 standards for both of these air 

basins by 2006 and the ozone standard by 2010. Ammonia is a precursor of PM10, 

particularly aerosol ammonium nitrate and ammonium sulfate. Volatile organics compounds 

(VOC) are precursors to ozone. Livestock waste produces appreciable amounts of VOC and 

ammonia emissions. 

Under the State law, the AQMD is required to adopt an Air Quality Management Plan 

(AQMP) that identifies a control strategy to demonstrate compliance with all State and 

federal ambient air quality standards.1

 To address these State and federal mandates, the 

1994, 1997 AQMPs, the 1999 amendment to the 1997 ozone SIP, and the 2003 AQMP 

included control measure (WST-01) for the control of ammonia and VOC emissions from 

livestock operations. PR1127 is designed to implement the 2003 AQMP control measure 

WST-01. 

 

1 California Health and Safety Code Section 40460(a) 
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PR 1127 3 June 2004 August 2004

Air Quality Regulations 

AQMD Rule 1186, PM10 Emissions From Paved and Unpaved Roads, and Livestock 

Operations reduces the amount of particulate matter entrained in the ambient air as a result of 

vehicular travel on paved and unpaved public roads and at livestock operations. Rule 1186 

restricts the times during which a dairy operator can grind hay. The restriction is dependent 

on extent of visible emissions. Also, livestock operations are required to control entrained 

road dust from unpaved access roads on the dairy operation. 

The 2003 AQMP includes control measure WST-01 as part of a comprehensive program to 

reduce sources of PM10 and ozone precursor emissions, e.g. ammonia and VOCs. The 

emission reductions can be achieved by the relocation and the resulting decrease in cow 

population, air quality benefits associated with water quality regulations, and by proposed 

control methods. The 2003 AQMP (as originally stated in the 1997/9 AQMP) establishes a 

“carrying” capacity (or “target”) for dairy emissions. This target is set to ensure attainment 

of the PM10 standards, as determined by the attainment demonstration. Emission reductions 

from livestock relocation outside of the Basin will be counted toward the WST-01 goal of a 

50% ammonia and 30% VOC emission reduction from the 1997 AQMP base year emissions 

(base year = 1993). However, it is becoming apparent that the 2006 emission reduction 

target can not be met with relocations alone. The anticipated emission reduction shortfall 

and the Basin’s severe air pollution problem relative to ozone, PM10 and PM2.5 necessitate 

further controls of ammonia and VOCs from dairy operations and livestock facilities. 

Control options described in the 2003 AQMP include altering livestock feed to reduce 

nitrogen content in resulting manure (urine and feces), removal of manure from the facility in 

a timely manner, storage of manure under conditions that produce less ammonia, promotion 

of aerobic rather than anaerobic conditions in the feed yard floors, corrals and manure 

stockpiles, and/or the application of enzymatic, pH adjusting and/or microbial solutions to 

the manure to reduce emissions. 

Prior to the approval of SB700 in September 2003, California state law exempted equipment 

used at agricultural facilities from the permit system of local air pollution control districts. 

Equipment used at agricultural facilities represents a significant source of air pollution 

throughout the state. With the exemption from permitting, agricultural facilities were not 

included in the state’s Title V permitting program required by the Federal Clean Air Act. 

The United States Environmental Protection Agency (USEPA) proposed disapproving the 

state’s Title V permitting program because of the exemption and the significant source of air 

pollution that agricultural operations represent. To avoid federal sanctions, on September 22, 

2003, Governor Davis signed SB700, which revised state law to remove the agricultural 

permitting exemption. SB700 was adopted to harmonize state and federal permitting 

requirements and to recognize the contribution to the air pollution problem that agricultural 

operations represent. In addition to correcting the deficiencies cited by USEPA, SB700 

mandates new permitting and pollution control requirements for agricultural sources in 

California and requires that agricultural sources be treated similar to other sources of air 

pollution. 

SB700 requires each district that is designated a serious federal non-attainment area for an 

applicable ambient air quality standard for PM as of January 1, 2004, to adopt, implement, 

and submit for inclusion in the state implementation plan (SIP), a rule or regulation requiring 

BACM and Best Available Retrofit Control Technology (BARCT) for agricultural practices 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 4 June 2004 August 2004

at agricultural sources of air pollution to reduce air pollutants from those sources for which 

that technology is applicable for agricultural practices by the earliest feasible date but no 

later than January 1, 2006. SB700 also requires each district subject to those requirements to 

comply with a schedule for public hearing, adoption, and implementation of the final rule. 

Adopted Rule 1186 and PR1127 would implement BACM at dairies as required by SB700. 

Permitting requirements for equipment at dairies will be addressed through other AQMD 

actions. Other SB700 requirements, such as whole farm permits, emission reduction permits 

for Large Confined Animal Farms (as defined by SB700) and BACM requirements for 

poultry and other livestock operations, will be addressed in future AQMD rulemaking. 

 Water Quality Regulations 

In the Chino Basin, high concentrations of animals per acre of land have resulted in the 

generation of large volumes of manure, (e.g. more than 1.3 million tons of manure was 

produced in 2002). Historically, the manure has been stored in the corrals, stockpiles and to 

a much smaller extent, in the holding ponds. The density of the livestock and the location of 

the dairies have limited the manure disposal options. Few dairies have had pasture land on 

which to spread the manure and there were only a few local composters. Due to these 

limitations, the majority of the manure was stockpiled at the dairy, hauled off site, stored in 

stockpiles or land applied to cropland as fertilizer. Animal waste in rainfall runoff from 

livestock operations in the Chino Basin and the San Jacinto Basin has caused groundwater 

pollution and impacted the quality of the area waterways, including the Santa Ana River, 

Prado Basin, San Jacinto River, Canyon Lake and Lake Elsinore. Percolation of rainfall and 

runoff through corrals and drainage from stockpiles contaminates the groundwater with 

nitrates and total dissolved solids (TDS). Therefore, proper management of wastes from 

dairies and other confines animal feeding operations (CAFOs) is necessary to protect the 

surface and groundwater. 

Based on analysis of the 2002 SARWQCB Annual Report, 314 dairy operations submitted 

annual reports to the Santa Ana Regional Water Quality Control Board. The majority of the 

Santa Ana and San Jacinto watersheds, which comprise the SARWQCB jurisdiction, lie 

within the Basin. All of the dairy operations under the SARWQCB jurisdiction are located 

within the Basin. The geographical location of the watersheds and dairy operations are 

shown in Figure 1. In 2002, the dairy operations contained approximately 253,000 lactating 

(milking) cows (CDFA). Two hundred and seventy-three dairy operations are located 

within the Chino Basin, 38 are within the San Jacinto Watershed and 3 are located in the 

Upper Santa Ana Region. In 2002, 1.3 million tons of manure was reported in the manure 

manifests submitted to the SARWQCB. 
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PR 1127 5 June 2004 August 2004

Figure 1: Santa Ana and San Jacinto Watershed Locations (SAWPA) 

From 1972 to 1994, the SARWQCB regulated the dairies by issuing individual waste 

discharge permits. In 1994, the SARWQCB adopted a General Waste Discharge 

Requirement, Order No. 94-7, for concentrated feeding operations, including dairies, in the 

Santa Ana Region. At the time, two desalters were scheduled to be built in the Chino Basin 

as well as the operation of a Chino Basin Co-composting facility. These facilities were 

expected to reduce the salt and nitrate load from the Chino Basin. However, only one 

desalter has been built and the co-composting facility did not remove the expected amount of 

manure from the SAWCQB Region. As a result, the salt load in the SARWQCB Region was 

not significantly reduced. During this time period (1994 – 1999), the dairies continued to 

stockpile the manure at the dairies, and land apply manure to local farm land. 

The SARWQCB has since re-evaluated the dairy and other AFO regulations in the 

SARWQCB Region and developed Order No. 99-11. This order complies with the federal 

Clean Water Act (CWA), which states that all concentrated feeding operations are point 

sources and are subject to NPDES permits. (The SARWQCB has deemed that all dairies, 

calf nurseries and heifer ranches in the SARWQCB Region are CAFOs and are subject to 

NPDES requirements). Order No. 99-11 regulates the storage of manure, discharge of 

manure and application as fertilizer in the Chino Basin and requires that the dairy operations 

comply with the following control options in order to minimize ground water contamination: 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 6 June 2004 August 2004

• Clean corrals and remove stockpiled manure at least twice a year (every 180 

days) 

• Two Clean Days per year – free of stockpiled manure 

• Application of manure as a fertilizer in the Chino Groundwater Basin is 

prohibited (with exemptions) 

In order to comply with Order No. 99-11, the dairies are required to prepare a manure 

manifest of the manure hauled away and submit the manifest with the annual report, in 

accordance with the SARWQCB annual report requirements. Compliance with the 

SARWQCB, Order No. 99-11, is factored into the emission reduction analysis and forms the 

basis of the PR1127 requirements. 

In January 2003, the U.S. Environmental Protection Agency (EPA) revised the regulatory 

requirements for concentrated animal feeding operations (CAFOs) under the Clean Water 

Act. The rule ensures that CAFOs take appropriate actions to manage manure effectively in 

order to protect the nation’s water quality. The rule revision strengthens the existing 

regulatory program for CAFOs. The rule requires all CAFOs to apply for a National 

Pollutant Discharge Elimination System (NPDES) permit. The new NPDES permit 

requirements pertain to beef, dairy, swine, veal calves and poultry CAFOs. In addition all 

CAFOs covered by NPDES permits are required to develop and implement a nutrient 

management plan (NMP). The nutrient management plan identifies manure management 

practices necessary to implement the effluent limitations guidelines and any other 

requirements in the permit. The nutrient management plan would include requirements to 

land apply manure, and process wastewater consistent with site specific nutrient management 

practices that ensure appropriate agricultural utilization of the nutrients. 

Dairies within the SARWQCB jurisdiction are required to either submit a engineered waste 

management plan (EWMP) or a nutrient management plan (NMP). EWMP’s are required for 

dairy operations that do not have the capacity for land application of manure within their 

dairy operation. 

Federal and state programs exist that aid the agricultural industry with environmental 

requirements. The federal, Environmental Quality Incentives Program (EQIP) is funded 

through the Farm Bill and is administered by the Natural Resources Conservation Service 

(NRCS). EQIP is a voluntary program that provides assistance to agricultural producers to 

meet Federal, State, tribal and local environmental requirements. 

The California Dairy Quality Assurance Environmental Program (CDQA) is administered 

through the University of California at Davis, cooperative extension programs and helps 

California dairy producers understand and meet federal, state, regional and local 

requirements for manure and water quality. An air quality component is currently being 

developed and will be added to the CDQA program. 

INDUSTRY PROFILE 

A dairy farm or facility is an agricultural operation directly related to the raising cows or 

producing milk from cows for the purpose of making a profit or for a livelihood. The USDA 

reports that there were 105,250 milk production operations and 9.2 million dairy cows in the 
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PR 1127 7 June 2004 August 2004

United States in the year 2000. California produced 19.2 percent of the milk in the United 

States and the state is ranked number one for milk production in the country. On average, 

California had 1.5 million dairy cows, 2,195 dairies in the year 2000. In California the 

average number of cows per dairy was 696 compared to the national average of 88. In 

Riverside and San Bernardino the average number of cows per dairy are 1092 and 842 

respectively. Dairying practices differ throughout the state, country and world. In the San 

Joaquin Valley and northern California the majority of the dairies are flush lane operations. 

The manure in the milking parlors and free stall barns are flushed with recycled lagoon water 

into the lagoons. Waste from the lagoons is land applied as a nutrient source to local 

farmland. Most dairy farms in the Basin are “dry lot corral” dairies. Dairy cows live in 

open corrals, with feed lanes usually along one side of the corral. Manure is generally 

cleared from the feed lane into the corral, and then periodically removed from the corral, 

either to on-site stockpiles or off-site. Current water quality regulations require clearing of 

on-dairy manure twice a year. 

Local Dairy History 

Historically, from the 1950’s until the early 1970’s, Los Angeles and Orange counties 

represented the center of dairy operations in Southern California. The city of Cerritos, 

originally named Dairy Valley, was one of the large dairy centers. Dairy Valley was the 

home to 100,000 cows on more than 400 dairies and 106,300 chickens on licensed poultry 

farms. Urban crowding, increased odor and nuisance complaints, traffic and drainage 

problems caused the dairies to move eastward to the San Bernardino Agricultural District or 

“Dairy Preserve”. 

During the 1930’s the Chino Valley “Dairy Preserve” in San Bernardino county contained 

117 dairies and 7,600 cows. The herds were small and ranged from 15 to 25 cows with 

family members supplying practically all the labor. By 1950, the number of cows in Chino 

Valley had doubled, but the dairy numbers had declined to 99. Between 1950 and 1970 many 

dairies sold their cows and milk quota because of the favorable prices resulting from the 

statewide marketing pool. However, other dairies increased their herd size for maximum use 

of their facilities and equipment. This resulted in an overall increase in the number of dairy 

cows in both San Bernardino and Riverside Counties. A large part of the increase was a 

result of the relocation of dairies from the Los Angeles and Orange County metropolitan 

areas to the Chino area. As dairying became more specialized, the average herd size 

increased. In 1991 there were 349 dairies. In 2002, there were 314 dairies. 

The high concentration of animals per acre of land in the Chino/Ontario area results in a 

large volume of manure stored in corrals, stockpiles and to a much smaller extent, holding 

ponds. This high density of livestock, as well as the location of dairies, limits manure 

disposal options. Few dairies have pastures on which to spread the manure, and there are 

only a few local composters that use the manure. Large quantities of manure are trucked to 

other areas of the Basin and to areas outside of the Basin, such as the Imperial County or San 

Joaquin Valley, for processing as fertilizer. In October of 1999, the Santa Ana Regional 

Water Quality Control Board (SARWQCB) approved comprehensive National Pollutant 

Discharge Elimination System (NPDES) regulations for local dairies. The NPDES regulates 

the removal of manure from dairies and the storage of stockpiles of manure. Under these 

regulations, manure must be removed from the dairies twice a year (approximately every 180 

days). This includes the scraping of corrals and removal of stockpiled manure. Storage of 

manure in stockpiles promotes anaerobic conditions and the generation of by-product gases. 
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PR 1127 8 June 2004 August 2004

In 1999, the Local Agency Formation Commission granted the City of Chino annexation 

rights to 7,000 acres and the City of Ontario to annexation rights to 8,600 acres of previously 

dedicated agricultural (e.g. dairy) land. Due to urbanization and economic reasons, some 

dairy and other livestock operations are leaving the Chino/Ontario area and are relocating to 

other areas such as the San Joaquin Valley, the northwestern United States, and Texas. 

Current Local Dairy Situation 

The Chino/Ontario area, which includes the former Agricultural Preserve, is a 15,000 acre 

area in southwestern San Bernardino and Riverside Counties which contains approximately 

300 dairies with over 250,000 cows, resulting in one of the densest dairy cow populations in 

the country. The resulting manure (feces and urine) from these dense herds of cows produces 

large amounts of ammonia in a relatively small area. This ammonia is a key contributor to 

ammonium nitrate; in peak PM10 areas a preliminary modeling study indicated that 

ammonia reductions in the former Agricultural Preserve area would lead to significant 

decreases of ammonium nitrate in peak PM10 areas (SCAQMD, 1993). (Other contributors 

to PM10 are NOx and SOx emissions from upwind mobile and stationary sources.) Other 

livestock facilities such as poultry and horse ranches are found to a much lesser extent in the 

Basin. It should be noted that livestock facilities are also present in other areas of the Basin, 

generally toward its eastern and northern boundaries. The spatial distribution of dairy and 

poultry operations is shown in Figure 2. 

Figure 2: Distribution of Poultry and Dairy Operations in the Basin 
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PR 1127 9 June 2004 August 2004

 

According to the Santa Ana Regional Water Quality Control Board’s (SARWQCB) annual 

inventory of the dairy industry, in 2002 there were 314 dairies in the Basin with 204,846 

milking cows, 36,201 dry cows, 75,582 heifers and 77,320 calves (“Results of 2002 Annual 

Report of Animal Waste Discharge Analysis”, May 8, 2003, SARWQCB). (Calves are cows 

up to 12 months old, heifers are cows from 12 to 24 months old, or until first breeding, 

milking cows are adult cows that are lactating and dry cows are adult cows that are not 

milked, generally 45 to 60 days before giving birth.) Most of the dairies are located in the 

Chino-Ontario-Norco region, with the remaining dairies in the San Jacinto watershed region 

(eastern Riverside County, near Moreno Valley-Lake Elsinore-Hemet) and Upper Santa Ana. 

The Chino-Ontario-Norco region is a 15,000 acre area in southwestern San Bernardino and 

Riverside counties, and has one of the densest dairy cow populations in the country. The 

resulting manure from these dense herds of cows produces large amounts of ammonia in a 

relatively small area. 

Most dairy farms in the Basin are “dry lot corral” dairies. Dairy cows live in open corrals, 

with feed lanes usually along one side of the corral (Figure 3-1). 

FIGURE 3-1: Cows at the FeedLane 

Manure is generally cleared from the feed lane into the corral (Figure 3-2) and then 

periodically removed from the corral to on-site stockpiles, to off-site locations or spread on 

cropland at the dairy as a soil amendment. 
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PR 1127 10 June 2004 August 2004

FIGURE 3-2: Cows at the Watering Trough in the Corral 

The high concentration of animals per acre of land results in a large volume of manure stored 

in corrals and stockpiles. Because most dairy operations are clustered in a relatively small 

area with a high density of dairy livestock herds, substantial amounts of manure are produced 

in a concentrated area. 

The Chino Basin is considered to have the highest concentration of dairy animals in the 

world within an area of less than 50 square miles. Stockpiles of manure and the application 

of manure to the ground in the Chino Basin have resulted in substantial groundwater 

pollution, specifically from total dissolved solids (TDS) and nitrate. Contaminated 

groundwater in the Chino Basin also adversely affects the quality of the Santa Ana River 

because groundwater from the Chino Basin contributes to the surface flow of the Santa Ana 

River. 

Beginning in 1992, and continuing through 1994, the SARWQCB regulatory approach for 

concentrated animal feeding operations (CAFOs) was to issue individual waste discharge 

requirements for each animal feeding operation. Changes in the location, size, number of 

animals, or operator of these facilities were frequent and necessitated continually rescinding 

existing waste discharge requirements and issuing new requirements. As a result, in 1994 the 

SARWQCB adopted Order No. 94-7, which outlined "general" waste discharge requirements 

for all CAFOs, including non-dairy related facilities. SARWQCB Order No. 94-7 expired in 

March 1999. 

In 1999, the Santa Ana Regional Water Quality Control Board enacted Order No. 99-11 

(NPDES No. CAG018001). Order No. 99-11, among other things, prohibits the stockpiling 

of manure at a dairy for more than 180 days and restricts land spreading of manure on 

croplands within the Santa Ana Region. Except for a small amount of manure spread on 

cropland at the dairy, manure is currently hauled from the dairies to composting facilities or 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 11 June 2004 August 2004

applied to cropland. Before Order No. 99-11, most manure was spread on local croplands in 

the Santa Ana and San Jacinto regions. In 2002, and with restrictions on manure spreading 

in the Santa Ana region (including the former Agricultural Preserve), most manure spread on 

croplands is spread in the San Jacinto region (42% of total manure), with about 19% of total 

manure now going out of the Basin. 

The manure handling practices carried out by the dairies are dictated by the type of dairy 

operation, size of operation, local water quality regulations, and type of off-site manure 

processing and utilization that is locally available to the dairies. As part of an AQMD 

contract study with Tetra Tech, Inc., four reports on dairy practices and controls were 

prepared: 

 

Report 1: Current Livestock Waste Management Practices in the Basin 

Report 2: Literature and National Program Survey 

Report 3: Identification and effectiveness assessment of control options 

Report 4: Recommendation of Control Options for the Basin 

Figure 4 was extracted from Tetra Tech’s Task 3 Report (Tetra Tech, November 2002) and 

shows the layout of a typical dairy production facility in the Chino Basin. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 12 June 2004 August 2004

Figure 4: Typical South Coast Dairy Production Facility 

The SARWQCB requirement of removing the manure from the dairies every 180 days 

allows for utilization of “off farm” technologies to process and/or utilize the manure. Once 

the manure is removed from the dairy, it can be hauled to a composter (enclosed or open 

windrow), digester or to an agricultural site for land application 

Land application and open composting are the two main manure disposal practices currently 

used. Open windrow composting is the current composting practice in the Basin. There is 

currently one composting facility in operation which is scheduled to cease operation by the 

year 2006. An enclosed composter is currently being constructed in the Basin that will 

process a limited amount of manure. 

 

The third manure disposal practice in the Basin is treating manure in anaerobic digesters. 

The Inland Empire Utilities Agency (IEUA) has built two types of digesters in the Basin; a 

plug flow and a complete mix digester. The biogas produced provides fuel for electric 

generators. The current plug flow digester utilizes wet manure and produces bio-gas to run 

micro-turbines and the Chino Desalter. The products are sent to a composter and the final 

product is sold as fertilizer. IEUA has built both types of digesters as demonstration units at 

their regional plants in the Basin. 

EMISSIONS INVENTORY 

The nitrogen in animal manure can be converted to ammonia by a combination of 

mineralization, hydrolysis, and volatilization. Once emitted, the ammonia can be rapidly 

converted to ammonium nitrate and ammonium aerosols by reactions with acidic species 

(nitric acid, sulfuric acid and ammonium bisulfate). Thus, the ammonia emissions contribute 

directly to formation of PM10 and PM2.5 in the air and can impact atmospheric visibility. 

Manure also emits VOCs through the processes of anaerobic and aerobic decomposition. 

Source testing was conducted by an independent contractor at five dairies in the Basin during 

two seasonal episodes in 1995, in order to assess the air emissions of PM10 precursors from 

livestock waste at dairies. The testing was conducted during both the winter and summer 

conditions. Flux measurements were conducted to generate speciated emission factors 

(lbs/yr) to estimate emissions from dairy wastes. Ammonia emission factors were measured 

to range from 9 to 20 pounds per year per cow. In 1997, the ammonia emissions inventory 

for all sources was updated for the Basin (ATC 2000). As part of this update, the 1995 dairy 

emissions study results were re-evaluated by Dr. Eric Winegar, an author of the original 

study. This re-evaluation of the original flux chamber data resulted in a composite ammonia 

emission factor of 51 lb/head/year for milking cows. 

The VOC emission factor is 12.8 lbs/head/year. This is the emission factor used by CARB 

and is based on a 1938 measurement study by Ritzman and Benedict. This study focused on 

measuring methane emissions from dairy cows using an early form of an environmental 

chamber. Successive literature studies have used these measurements to establish a VOC 

emission factor for dairy waste emissions. (In the 1997, 1999, and 2003 AQMPs, the AQMD 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 13 June 2004 August 2004

used an emission factor of 16 lbs VOC/head/year, based on a slightly different analysis of the 

data.) CARB is supporting additional dairy VOC emission studies, but the 12.8 lbs 

VOC/head/year emission factor is the one currently recommended by CARB. 

An emission factor in terms of tons of manure was calculated for both VOC and ammonia 

emissions by incorporating the assumption that a cow produces, on average, 5.25 tons of 

manure per year. Emissions factors of 0.005 ton/year of ammonia and 0.002 ton/year of 

VOC per ton of manure were established. 

 

Based on SARWQCB the dairy animal population (milking cows, dry cows, hiefers and 

calves) within the District has decrease from the 1993 base year amount of 514,000 head to 

the 2002 value of 394,000, a reduction of approximately 23%. This decrease is expected to 

continue as the Chino Basin becomes more urbanized. The urbanization is being driven by 

the annexation of the agricultural land by the cities of Ontario and Chino. At the current rate 

of attrition (approximately 2% per year), the dairy population is expected to be 

approximately 362,000 head in 2006. This corresponds to a 8% decrease from the 2002 

levels. 

The following assumptions were used in the emission calculations: 

1. Emission Factors: 

a. Ammonia: 

i. 51 lbs/head/year (used to calculate total ammonia emissions) 

ii. 0.005 ton/ton of manure (the conversion is necessary since the analysis 

depends on the subsequent fate of the manure; emission factor determined 

by dividing total ammonia emissions per year by total manure produced) 

iii. Emission factor is for an adult cow, based on 1995 Schmidt study 

methodology. Emission factor for heifers and calves are reduced 

proportionately to the manure they produce (SARWQB estimates of 4.1 

tons/year manure for adult cows, 1.5 tons/year for heifers and 0.6 

tons/year for calves). [Ammonia emissions are emissions from manure 

only. Emission estimates do not include ammonia emitted from either the 

cow or cow urine.] 

b. VOC: 

i. 12.8 lbs/head/year (used to calculate total ammonia emissions) 

ii. 0.002 ton/ton of manure (the conversion is necessary since the analysis 

depends on the subsequent fate of the manure; emission factor determined 

by dividing total VOC emissions per year by total manure produced) 

iii. Emission factor is for each animal, regardless of age, per ARB’s 

methodology. [As noted above, this is different then the 16.0 lbs/head/year 

factor used in the PR1127 preliminary draft staff report, the 2003 AQMP 

and previous AQMPs.] 

c. PM10: 

i. 1.78 lbs/head/year. 

ii. Emission factor is for each animal, regardless of age, per ARB’s 

methodology. 

2. Activity 

a. Actual animal counts from 1993 through 2002 

b. Assume a 2% decrease in cows per year from 2002 through 2010. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 14 June 2004 August 2004

3. Source and destination of amount of manure removed and/or processed : SAQRWCB 

2002 Annual Report Analysis 

 

4. Emissions = emission factor x activity 

Impact of Existing Manure Management Practices on Emission 

Reductions 

As mentioned earlier, the dairies are subject to the manure handling and storage requirements 

of SARWQCB Order No. 99-11. The dairies are required to haul the manure off the facility 

within 180 days of removal from the corrals. A manifest of the manure hauled away is 

submitted with an annual report to the SARWCQB. The manure is sent off-site to a digester, 

composter, or land applied within or out of the SARWQCB Region. Table 1, from the 

SARWQCB, 2002 Annual Report Analysis, quantifies the percentage of the manure removed 

form the different dairy areas (i.e. Chino Basin, San Jacinto Watershed and the Upper Santa 

Ana Watershed) and the disposal location. 

Table 1: Summary of Manure Handling In SARWQCB Region (2002 Report) 

 Manure Source 

Disposal Location 

Dairies 

in the 

Chino Basin

Dairies in the

San Jacinto 

Watershed 

Dairies in the 

Upper Santa 

Ana Watershed 

Total 

Local Cropland (on Dairy) 1.35% 1.79% 0.0% 3.14%

Local Stockpile (on Dairy) 7.27% 0.03% 0.01 7.30%

Composting facility (off 

dairy) 16.9% 0.0% 0.0% 16.9%

Chino Basin (land 

application off dairy) 9.2% 0.45% 0.0% 9.65%

Sent Out of Region* 19.2% 0.08% 0.0% 19.10%

San Jacinto Watershed 

(land application off dairy) 27.92% 14.11% 0.12% 42.15%

Upper Santa Ana 

Watershed (land 

application off dairy) 1.22% 0.00% 0.15% 1.37%

Total 83.28% 16.46% 0.28% 100.0%

 * Out of Region refers to the SARWQCB Region 

The new water quality regulation (SARWQCB Order No. 99-11) expedites the manure 

removal from dairies, limits and sets manure incorporation standards for land spreading of 

manure, and eliminates historical stockpiles of manure in and around the dairies. Because 

these regulations affect manure, the emissions per ton of manure must be calculated to assess 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 15 June 2004 August 2004

the emission reductions associated with the water quality regulations. Manure production is 

known from the SARWQCB’s Annual Report of Animal Waste Discharge. 

The estimated impact of removing historical stockpiles is calculated by multiplying the tons 

of historical stockpiles that have been removed (94,000 tons, according to the SARWQCB) 

by the emissions factor per ton of manure. 

The estimated impact of the land application regulations (e.g., agronomic spreading rates, 

expeditious soil incorporation) is a 23% reduction in emissions multiplied by 0.5, since the 

reductions only occur after the manure is removed from the dairies, which occurs twice a 

year. The control efficiency of 23% is based, in part, on staff’s review of Tetra Tech’s Task 

1 and Task 2 reports (see also Appendix A). Thus, the overall reduction effectiveness of the 

new land spreading regulations in is 11.5% of the manure produced that is land applied in the 

Basin. 852,204 tons of manure was land applied in 2002, based on SARWQB data. 

Also, in response to current and proposed water quality regulations, manure composting 

operations were begun in 1995. These operations process over 200,000 tons of manure per 

year. Based on flux results of the 1995 PM10 Technical Enhancement Program (PTEP) 

studies of dairy and open-windrow composting operations, emissions are 75% less at the 

composting operations compared to manure emissions at the dairy. Reductions from 

composting can only occur after the manure is removed from the dairy (twice a year), so 

again, the control effectiveness is multiplied by 0.5. Thus, the overall reduction 

effectiveness is 37.5% for manure that is composted in open windrows and near 50% for 

enclosed and controlled composting facilities. 226,415 tons of manure was composted in 

open windrows in 2002. 

In response to the water quality regulations and the energy crisis, anaerobic digesters have 

been constructed and are currently operating. These digesters create “biogas” used as fuel 

for power generation equipment. The remaining digested solids are finished or near finished 

compost. The digester essentially eliminates VOC emission from the manure as anaerobic 

bacteria convert organic matter to biogas. Also, digesters require the freshest possible 

manure. Current digester programs scrape the feedlanes at the dairies daily and immediately 

transport it to the digesters. Since all the manure emissions are gone immediately (rather 

than waiting the 180 days until the corral is cleared), the removal factor is 1.0. Thus, the 

overall control effectiveness for manure sent to a digester is 99%. Demonstration projects 

for anaerobic digesters began in 2002, but only small amounts of manure were digested in 

2002. 

Of course, any manure sent out of the Basin does not contribute emissions within the airshed. 

Multiplied by the 0.5 removal factor to account for the manure’s presence in the first 180 

days, the overall effectiveness of removing manure from the Basin is 50%. 255,889 tons 

(about 19%) of manure was shipped out of the Basin (generally to San Joaquin Valley and 

Imperial County), based on 2002 SARWQCB data. (Although the Basin’s boundary does 

not exactly match the jurisdiction of the SARWQCB and it water basins, further analysis of 

the SARWQCB database concerning long-range manure transport indicates that this 

assumption is a good one). 

Emission reductions were calculated by multiplying the amount of manure removed and/or 

processed by the manure emission factor and a total control effectiveness. Partial emission 

reductions are taken for the land application of manure and windrow composting as listed 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 16 June 2004 August 2004

under control effectiveness in Table 2. The source extent or the percentage of emission 

reduction achieved due to removal from the dairy is also listed in Table 2. A 50 percent 

emission reduction was assumed for all manure that is removed approximately twice 

annually. The control effectiveness represents the percentage of emission reduction that can 

be achieved by the various manure disposal options. 

Table 2 : Total Control Effectiveness of Current Manure Practices 

Type of Disposal Practice % 

Control 

Effectiveness 

Removal 

Factor [0 -1] 

Total % Control 

Effectiveness * 

Land 

Application 

23% 0.5 11.5% 

Composting 

(open windrow) 

75% 0.5 38.5% 

Composting 

(enclosed) 

95% 0.5 47.5% 

Digester (plug 

and complete 

mix) 

99% 1.0 100% 

Manure: Sent 

out of Basin 

100% 0.5 50% 

* Total % Control Effectiveness = Practice Control Effectiveness X 

 Removal Factor 

Table 3 describes the manure disposal destinations for future years, based on historical 

destinations and changes in air and water regulations. Table 4 lists the emission estimates 

without the implementation of PR1127 (e.g. reductions due to relocation and water quality 

regulations). The emission reductions assume that all operations such as composting and 

land application are maintained at the 2002 rate in terms of percentage of manure with the 

exemption of the digesters. It is assumed that the digesters are on line after 2002 and that the 

open windrow composter ceased operation in 2005. 

 

Table 3: Manure Disposal For Future Years 

Manure Destination 2006 tons manure 

per year 

2010 tons manure 

per year 

Land Application in Region 937,000 835,000 

Sent out of Region 256,000 256,000 

Open Windrow Composting 0* 0* 

Rule 1133.2 Composting 7,500 7,500 

Digester (Feed Lane Cleaning) 27,400 27,400 

*Current open windrow facility will close as of 2006. 

*Rule 1133.2 effectively restricts open windrow composting. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 17 June 2004 August 2004

Table 4: Emission Estimates (tons/day) Without PR1127 

2006 VOC 2010 VOC 2006 ammonia 2010 ammonia 

Baseline 6.35 5.80 18.00 16.43 

Reductions 1.37 1.31 3.89 3.72 

Remaining Emissions 4.98 4.49 14.10 12.71 

PROPOSED CONTROL TECHNOLOGIES AND PRACTICES 

The manure handling practices carried out by the dairies are dictated by the type of dairy 

operation, size of operation, local water quality regulations, and type of off-site manure 

processing and utilization that is locally available to the dairies. An AQMD contract study 

by Tetra Tech included an assessment of current local waste management practices, a 

literature review of potential controls and practices to reduce air emissions, identification and 

assessment of potential local control options and recommendations. The results of the study 

are in the following reports (see reference section for full titles): 

Report 1: Current Livestock Waste Management Practices in the Basin 

Report 2: Literature and National Program Survey 

Report 3: Identification and effectiveness assessment of control options 

Report 4: Recommendation of Control Options for the Basin 

The study by Tetra Tech, Inc. has identified the many control technologies and practices that 

could reduce air emissions from livestock waste. The manure handling practices are 

classified as “on-dairy” or “off-dairy” technologies. Based on the study, the technologies, 

practices or regulations that will reduce emissions and are currently applicable to the dairy 

practices in the Basin are the following: 

1. Water Quality Regulations 

2. More frequent removal of manure from dairies 

3. Restrictions on amount and method of land application of manure 

4. Open Composting 

5. In-vessel aerated static pile composting 

6. Rule 1133.2 composting 

7. Anaerobic Digesters 

8. Out of Basin disposal 

A review of the manure management control options listed above is given in Appendix A. 

The SARWQCB requirement of removing the manure from the dairies every 180 days 

allows for quick utilization of “off farm” technologies to process and/or utilize the manure. 

Once the manure is removed from the dairy, it can be hauled to a composter, digester or to a 

agricultural site for land application. PR1127 would increase that frequency to 4 times per 

year, no shorter than 60 days apart and at least one clearing in the months of November 

through December. 

Controlled composting of manure is composting at a facility where the first stage of 

composting is conducted within an enclosure and emissions from the enclosure (and aeration 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 18 June 2004 August 2004

system, if any) are vented to an air pollution control device(s) permitted by the AQMD. Air 

pollution control devices include, but are not limited to, bio-filters, scrubbers, etc. 

An anaerobic digester is a tank or vessel system permitted by the AQMD that excludes 

oxygen and in which a sludge or liquid effluent is modified by the action of anaerobic 

bacteria. These systems are typically used to produce methane or biogas as fuel for power 

generation equipment. The remaining solids from the process can be used as a soil 

amendment or further composted or otherwise processed. 

A fabric in-vessel composter is an aerated static pile compost system that is under positive 

pressure and is covered by a plastic or fabric material with ventilation holes. The system 

consists of a containment vessel such as an elongated plastic bag which contains the 

composting material and uses forced aeration to maintain and control aerobic composting 

conditions within the bag. The forced aeration is provided by supplying air with an electric 

blower through perforated pipe that runs inside the full length of the bag. The raw material 

to be composted is placed in the bag with a compost-bagging machine. The bagger blends 

the compost material with required amendments and grind the material to the required size. 

The compost cycle is approximately 4 months. The final product can be used as compost and 

soil amendments. Although this type of system may meet Rule 1133.2 requirements for cocomposting operations (resulting in an 80% decrease in emissions compared to open 

windrow composting and a total of 95% reduction from raw manure emissions), under 

PR1127, they would not have to meet Rule 1133.2 requirements as long as they met the 

PR1127 requirements for alternative manure composting operations. For the purposes of this 

analysis, fabric in-vessel systems are assumed to provide a 50% reduction from open 

windrow emissions, yielding an overall effectiveness of 88%. The 50% reduction 

effectiveness was assumed based on staff analysis of the emission reduction effectiveness of 

open aerated static piles, the PR1127 requirements that both active and curing phases of the 

process must occur in the enclosed vessel, and the close contact of emission gases to the 

composting material and water condensation on the vessel walls. Testing proposed by the 

Inland Empire Utility Agency, which would begin in the summer of 2004, would allow the 

testing of the emission reduction effectiveness. PR1127 requires the annual testing of any 

alternative manure composting operation. Based on these test results, staff will assess the 

alternative manure composting technologies. Subsequent to that analysis, staff may 

recommend additional performance standards and/or control equipment for these systems. 

Since the other control options identified by the survey can not be sufficiently quantified at 

this time, they are not incorporated in the proposed rule. AQMD staff will continue 

supporting research and development of other potential control options. 

In the absence of more specific information, the San Joaquin Valley Air Pollution Control 

District has assumed a default PM10 control effectiveness of ten percent for dairy BMPs in 

their analysis of their rule 4550. 

Total Emission Reduction Impacts (With PR1127) 

The control effectiveness for various manure management practices with implementation of 

PR1127 are listed in Table 5. The basis for calculation is the same as Table 2. The removal 

factor is changed to 0.75 for all practices except for the digester which remains at 1.0. The 

removal factor is increased to account for the increased frequency of corral cleaning to 4 

times per year as required by the PR1127. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 19 June 2004 August 2004

Table 5: Total Control Effectiveness of Manure Practices with PR1127 

Type of Disposal Practice % 

Control 

Effectiveness 

Removal 

Factor [0 -1] 

Total % Control 

Effectiveness * 

Land Application 23% 0.75 17.3% 

Composting 

(Fabric-in-vessel) 

88% 0.75 66.0% 

Composting 

(enclosed) 

95% 0.75 71.3% 

Digester (plug 

and complete 

mix) 

99% 1.0 100% 

Manure: Sent out 

of Basin 

100% 0.75 75% 

*Total % Control Effectiveness = Practice Control Effectiveness X Removal Factor 

 * Assume Open Windrow Composting is not available in SCAB 

Table 6 describes the manure disposal destinations for future years, based on historical 

destinations, changes in air and water regulations, and the effect of PR1127. Table 7 lists the 

emission estimates with the implementation of PR1127. Table 8 lists the emission reductions 

that are solely due to the implementation of PR1127 (e.g., without the impact of relocation 

and water quality regulations). It is assumed that the amount of manure composted (now in 

alternative manure composting operations) and shipped out of the basin are maintained at the 

2002 rate in terms of tonnage of manure and that the corrals are cleared at least 4 times per 

year. By 2006, it is assumed that open windrow manure composting has been phased out in 

the District and replaced with an fabric-in-vessel system. The analysis also assumes that the 

digesters are on-line and processing manure at a rate as projected by IEUA, and that 

remainder of the manure is sent out of the region. 

Table 6: Manure Disposal For Future Years with PR1127 

Manure Destination 2006 tons manure 

per year 

2010 tons manure per 

year 

Land Application in Region 715,000 608,000 

Sent out of Region 256,000 256,000 

Open Windrow Composting 0* 0* 

Alternative Manure Composting 

(e.g. fabric in-vessel) 

226,000 226,000 

Rule 1133.2 Composting (enclosed) 7,500 7,500 

Digester (Feed Lane Cleaning) 27,400 27,400 

* Current open windrow facility will close as of 2006. Rule 1133.2 effectively restricts 

open windrow composting. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 20 June 2004 August 2004

 

 Table 7: Emission Estimates (tons/day) With PR1127 

2006 VOC 2010 VOC 2006 ammonia 2010 ammonia 

Baseline 6.35 5.80 18.00 16.43 

Reductions 2.56 2.47 7.26 6.99 

Remaining Emissions 3.79 3.33 10.73 9.44 

Table 8: Emission Reductions (tons/day) From PR1127 Alone 

2006 VOC 2010 VOC 2006 ammonia 2010 ammonia 

Remaining Emissions 

Without PR1127 

4.98 4.49 14.10 12.71 

Remaining Emissions 

With PR1127 

3.79 3.33 10.73 9.44 

PR1127 Reductions 1.19 1.16 3.37 3.27 

Comparison to WST-01 Targets and the 2003 AQMP 

Table 9 compares the remaining emissions after the implementation of PR1127 to the target 

levels described in the 2003 AQMP control measure WST-01: a 50% reduction in ammonia 

and a 30% reduction in VOC from historical baseline levels. As can be seen in Table 9, 

emission levels after the implementation of PR1127 are below the target levels set in the 

2003 AQMP control measure WST-01. 

Table 9: Comparison of Remaining Emissions after PR1127 with WST-01 

Target Levels (tons/day) 

VOC Ammonia 

Historical baseline emissions 

(1993) 

10.03 25.93 

“Target” emission levels 7.02 12.97 

2006 Remaining Emissions 

With PR1127 

3.79 10.73 

The 2003 AQMP used a slightly different emissions methodology (e.g., different VOC 

emission factor, no emissions from abandoned external stockpiles). Adjusting the 2006 

remaining emissions after the implementation of PR1127 to the “emissions currency” of the 

2003 AQMP, remaining emissions are 4.6 tpd VOC and 8.8 tpd ammonia. This compares 

with 2003 AQMP WST-01 remaining emissions of 6.8 tpd VOC and 10.6 tpd ammonia in 

2006. 

Alternate Future Analysis 

In the weeks before the release of this report, AQMD staff has received new information 

concerning the relocation of dairies from the District. The industry indicates that relocation 

may occur faster than the 2% per year assumed in the staff analysis. Although staff does not 

have definitive proof of faster relocation, staff has analyzed the impact of a higher rate of 

relocation. This section analyzes the potential impact on the emission analysis if relocation 

occurs at a faster rate (~10% per year) than assumed by the staff analysis (2% per year). 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 21 June 2004 August 2004

According to information from Milk Producers’ Council (memorandum dated April 15, 

2004), CDFA data for 2003 indicates that 38 dairies and ~31,000 cows left the Southern 

California area during that year. By Milk Producers’ Council estimates, there are currently 

approximately 230 dairies within the AQMD’s jurisdiction. Their near-term relocation 

estimates are summarized in the following table: 

Table 10: Near-term Local Dairy Relocation (source: Milk Producers’ Council) 

# of 

dairies 

~# in 2-5 year escrow Remaining 

Eastvale area 

(Riverside County) 

30 30 0 

City of Chino 25 22 3 

City of Ontario 140 105 35 

San Jacinto area 35 9 26 

TOTAL 230 166 64 

Although this data does not completely correspond to SARWQCB data and the number of 

dairies is not directly proportional to the number of cows, if these projections hold true, it 

does suggest a significant acceleration of the relocation rate of local dairies. To test the 

impact of such an accelerated rate of relocation (over a 75% reduction in cows by 2010), 

AQMD staff has re-run the technical analysis presented above assuming a 10% per year 

relocation rate (compared to the 2% per year in the staff analysis). The results of the alternate 

future analysis are presented in Table 11. As would be expected, the remaining emissions 

are significantly less than if relocation only occurs at a 2% per year rate. PR1127 would still 

produce emission reductions (e.g. 0.13 tpd VOC and 0.36 tpd ammonia in 2010) for the 

accelerated relocation scenario. 

Table 11: 2010 Alternate Future Emissions With PR1127(tons/day) 

VOC Ammonia 

Current 

Analysis 

Alternate 

Future 

Current 

Analysis 

Alternate 

Future 

Baseline 5.80 1.38 16.43 3.91 

Reductions 2.47 0.53* 6.99 1.49** 

Remaining Emissions 3.33 0.85 9.44 2.42 

 * 0.13 tpd of the VOC reductions from PR1127 

 ** 0.36 tpd of the ammonia reductions from PR1127 

SUMMARY OF PROPOSED RULE REQUIREMENTS 

A summary of the requirements of PR 1127 is provided below. A copy of the proposed 

Rule 1127 is included in Appendix B. 

Purpose and Applicability

The purpose of PR1127 is to reduce ammonia, VOC and PM10 emissions from livestock 

waste, consistent with the requirements of AQMP control measure WST-01 and California 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 22 June 2004 August 2004

Senate Bill (SB)700. Applicable operations would include dairies, heifer, and calf farms 

(unless exempt) within the SCAQMD’s jurisdiction. It also applies to manure processing 

operations, such as composting operations and anaerobic digester. 

Definitions 

This subdivision will include new definitions added for the following terms used in PR1127: 

o Alternative manure composting operation 

o Anaerobic digester 

o Dairy farm 

o Existing dairy operation 

o Manure processing operation 

o Operator 

Requirements

The requirements of PR 1127 apply specifically to dairy farms and the disposal of manure. 

There are four primary requirements: Best Management Practices, Manure Disposal 

Requirements, Manure Processing Requirements and Reporting/Recordkeeping 

Requirements. 

Best Management Practices (BMP) 

BMPs are required by SB700 and are proposed to reduce direct emissions and increase the 

emission reduction effectiveness of certain manure processing requirements. The proposed 

BMPs would require all farms on or after December 1, 2004 to: 

1. Implement at least one of the following manure harvesting protocols to minimize 

fugitive dust emissions: 

a) Scrape or harrow in early morning (before 9 a.m.) only unless the moisture 

content is greater than 20% (as determined by specified test method); OR 

b) Clear corrals of manure such that an even surface of compacted manure remains 

on top of the soil. Do not scrape down to soil level. Pulling, rather than pushing, 

blades are recommended; OR 

c) Water corral before manure harvesting to reduce dust through increased surface 

moisture (this measure is not recommended for lactating cows). 

2. Minimize water in corrals by 

a) Identifying and eliminating water leaks from trough and trough piping: and 

b) Complying with corral drainage standards in the Engineered Waste Management 

Plan. 

3. Feedlanes must be paved at least eight feet on the corral side of the fence. 

4. Effective January 1, 2005, clear corrals of manure in excess of 3 inches deep at least 

four times per year and not less than 60 days between clearings. Notification and 

rRecordkeeping are is required. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 23 June 2004 August 2004

5. Effective January 1, 2005, clear all on-dairy stockpiles within one month of the last 

corral clearing day and no more than 3 months after the date that the previous 

stockpiles were last completely cleared. Notification and rRecordkeeping are is 

required. 

Manure Disposal Requirements 

On or after January 1, 2006, a dairy operator disposing of manure within the jurisdiction of 

the South Coast Air Quality Management District shall only remove or contract to remove 

that manure from their dairy to : 

1) approved agricultural land within the SCAQMD; or 

2) a manure processing operation approved in accordance requirements below. 

Manure Processing Operation Approval Requirements 

Manure processing requirements are designed to reduce ammonia and VOC emissions from 

unprocessed manure. Approvable manure processing operations include an anaerobic 

digester; or a Rule 1133.2-compliant composting facility; or an alternative manure 

composting facility as defined in the proposed rule. Approval procedures are described. An 

alternative manure composting facility must apply for approval with the SCAQMD and meet 

operation plan and testing requirements. 

Reporting and Recordkeeping Requirements

Reporting and recordkeeping requirements are necessary to ensure rule compliance, 

enhance enforceability and meet certain SB700 requirements. 

1) No later than January 1, 2005, the operator of an existing dairy farm shall submit 

a PR1127 notification to the SCAQMD, including operator’s name, farm location, 

and contact information. 

2) No later than 30 days after operations begin at a new dairy farm or an existing 

farm under a new operator, the operator shall submit notification to the 

SCAQMD, including operator’s name, farm location, and contact information. 

3) After January 1, 2007, an annual report is to be submitted by an operator by the 

15th of January of each year. The report shall include animal population and 

amount of annual manure removed to various destinations. 

4) Records should be maintained at the dairy farm for three years, or five years if a 

Title V facility. 

Test Methods

Moisture content of manure is to be determined by using an electrical conductivity or 

microwave moisture meter, or other AQMD-approved method in the prescribed manner. 

Fees

Operators of farms or facilities subject to reporting and recordkeeping requirements shall be 

assessed applicable filing and evaluation fees pursuant to SCAQMD Rule 306. 

Exemptions
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 24 June 2004 August 2004

1) Farms with less than 50 cow, heifers, and/or calves are exempt from this rule. 

2) An operator can be exempt from one corral clearing per year if conditions are 

such that the manure in the corral is too wet (above 50% moisture content) to 

remove. (Attempting to remove manure that is too wet can damage the “hard 

pan” layer of manure used as bedding by the cows and that serves as a barrier to 

percolation to ground water.) For comparison, manure fresh from the cow is 

typically 85 to 88% moisture and “corral dry” manure, as used in accounting by 

the SARWQCB, is approximately 33% moisture.

3) Alternative manure composting operations are exempt from Rule 1133.2 

requirements if they meet the minimum operating parameters for in-vessel 

composting. 

4) Dairies that are removing all feedlane manure to a digester no fewer than 6 days 

per week are exempt from the corral clearing / stockpile removal requirements in 

paragraphs (d)(4) and (d)(5). (Water quality regulations still require twice yearly 

stockpile removal.)

Alternative Control Options

A person may comply with a plan for achieving equivalent emission reductions through 

alternative control measures. The plan must be approved by the SCAQMD, CARB and the 

USEPA before implementation and rule compliance. 

COST-EFFECTIVENESS 

Cost-effectiveness is calculated by dividing the estimated compliance costs of a proposed 

regulation by the estimated emission reductions. These costs were divided by the estimated 

emission reductions in order to obtain a cost-effectiveness estimate. 

The costs that dairy operations incur to dispose of manure include a tipping fee at manure 

processing facilities and farms as well as transportation costs to haul the manure to the 

disposal locations or facilities outlined above. Table 12 shows the manure disposal costs 

based on a dry ton manure basis for the various disposal options. Hauling costs are on a 

per-ton basis and include the current related corral clearings (twice a year). The cost of 

additional corral clearings is assumed to be an additional $150 per farm per clearing. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 25 June 2004 August 2004

Table 12: Cost of Manure Disposal Options (adjusted to tipping-fee basis)

Manure Disposal Option Tipping Fee 

($/ton)

Hauling Cost 

($/ton) 

Total Cost 

($/ton)

Shipping in SCAB* $1.50 $6.00 $7.50

Shipping out of SCAB (backhaul benefit**) $1.50 $14.50 $16.00

Shipping out of SCAB (no backhaul benefit) $1.50 $23.50 $25.00

Open Composting*** $12.00 $6.00 $18.00

Anaerobic Digestion*** (IEUA - existing) $4.00 $16.00 $20.00

Fabric-In-Vessel Composting**** $16.74* $6.00 $22.74*

* Milk Producers’ Council 

** Backhauling refers to the practice of using the return trip of a manure hauling for transporting other goods back 

to the dairy farmer, such as transporting feed. 

***Inland Empire Utilities Agency 

**** CTI System, Ag Bag International. Costs include land, machinery, bags, blowers, electricity, and labor. 

The costs that the dairy farms would incur under PR 1127 is the additional cost of disposing 

of the manure though an alternative composting system compared to disposing of the 

manure by land application within the Basin and the cost of more frequent corral clearing (4 

vs. 2 per year per farm). The analysis assumes that with PR1127, manure currently sent to 

the open windrow manure composting facility in Chino (which closes to new feedstock in 

2006) will go to fabric in-vessel composting operations. In the absence of these facilities, 

the base case assumes that this manure will be land spread in the Basin (least cost option 

currently available). 

The cost-effectiveness analyses uses the Discounted Cash Flow (DCF) method to compute 

the present value of the proposed rule’s costs and the more stringent option over a 10-year 

period (the assumed equipment lifetime) with a 4 percent real interest rate, which gives the 

present value factor of 8.111. DCF cost effectiveness can then be calculated as: 

Cost Effectiveness = Additional Compliance Cost x 8.111

 PR1127 Emission Reductionstons/year x 10 years 

 

Where: 

1. Additional Annual O&M Compliance Cost = (FIVcost/ton–In-basin spreading)*tons 

manure + extra corral clearing costs 

 =( 22.74-7.50)*226,415+78,180 

 =$3,529,000 

2. PR1127 Emission Reductionstons/yea =(Annual Emission Reductions with PR1127) – 

(Annual Emission Reductions without PR1127) 

The annualized emission reductions for PR1127 are 423 tons/year VOC and 1194 tons/year 

ammonia. PR1127 cost-effectiveness, as determined by the DCF method described above, 

is shown in Table 13. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 26 June 2004 August 2004

Table 13: PR1127 Cost-Effectiveness

Pollutant Emission reductions Cost-effectiveness 

VOC 423 tons/year $6,770/ton 

Ammonia 1194 tons/year $2,400/ton 

Combined 

(VOC+ammonia)

1617 tons/year $1,770/ton 

INCREMENTAL COST-EFFECTIVENESS 

Health and Safety Code Section 40920.6 requires that an incremental cost-effectiveness 

analysis be performed for a regulation which identifies more than one control option to meet 

the emission reduction objectives relative to the precursors to ozone, CO, SOx, and NOx. 

Incremental cost-effectiveness is defined as the difference in costs divided by the difference 

in emission reductions between one level of control and the next more stringent control. 

The incremental cost-effectiveness analyses use the Discounted Cash Flow (DCF) method 

to compute the present value of two rule options, one being more stringent, over a 10-year 

period (the assumed equipment lifetime) with a 4 percent real interest rate, which gives the 

present value factor of 8.111. For the purpose of calculating incremental cost-effectiveness 

only, a more stringent option would be constructing and sending manure to an anaerobic 

digester instead of an alternative manure composting operation. The amount of manure to 

be processed by either technology is assumed to be 75 tons/day or 27,375 tons/year (dry 

tons). This is the amount of manure currently being used at the IEUA digester. 

The costs and emission reductions used in calculating the incremental cost effectiveness of a 

digester compared to a fabric in-vessel composting system are summarized in Table 14. For 

the digester, costs are listed for two scenarios; the first assumes that no electricity revenue 

can be used to subsidize the cost of the anaerobic digester and the second assumes that a 

revenue of $0.08 per KwH is realized from electricity cost savings at a facility that the 

digester is sited in. The first scenario is most likely if the dairy operators built a digester for 

control reasons, but were unable to use much of the electricity produced on site. (Currently, 

several regulatory and other barriers exist that prevent the sell-back of electricity to the grid, 

i.e., running the electricity meter backwards when producing more energy than consumed.) 

The second scenario is based on an IEUA-type situation where the utility can use the 

electricity produced 24-hours a day to reduce facility electricity costs. The two scenarios 

are high and low cost scenarios for local digesters. Tables 15 and 16 summarize the cost 

effectiveness and incremental cost effectiveness for PR1127. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 27 June 2004 August 2004

Table 14:Summary of Costs and Assumptions 

Costs and 

Assumptions 

Fabric 

In-Vessel 

Anaerobic Digester 

(without electricity 

benefit) 

Anaerobic Digester (with 

electricity benefit at $0.08 

/ KwH) 

Capital Costs $8,118,700 $8,118,700 

Operating and 

Maintenance Costs $624,000 $562,000 $(127,000) 

Operating and 

Maintenance Costs – 

for the dairy (vacuum 

and hauling costs) $273,750 $273,750 

Capital costs + 

8.111*O&M $5,064,000 $14,900,000 $9,310,000 

Absolute VOC 

Emission Reduction* 

(tons/yr) 34 51 51 

Absolute Ammonia 

Emission Reduction* 

(tons/yr) 96 144 144 

 * compared to raw manure emissions 

Table 15−Absolute Cost Effectiveness

Cost Effectiveness VOC Ammonia VOC & Ammonia

Fabric In-Vessel $15,000 $5,300 $3,900 

Digester (no electricity cost 

recovery) 

$29,000 $10,300 $7,640 

Digester Scenario (recover 

electricity at $.08 /KwH) 

$18,300 $6,460 $4,770 

 Table 16− Incremental Cost Effectiveness Compared to Fabric In-Vessel

Incremental Cost 

Effectiveness 

VOC Ammonia VOC & 

Ammonia 

Digester (no electricity 

cost recovery) 

$58,000 $20,500 $15,000 

Digester (recover 

electricity at $.08 /KwH) 

$25,000 $8,800 $6,500 

COST AND AFFORDABILITY 

The cost of implementing PR 1127 is approximately $3.53 million per year starting in 2006. 

This amount is based on the increase in tipping fee from the current practices of land 

application to the tipping fee for a fabric-in-vessel composter and the cost of 2 additional 

corral clearings per year per farm. Assuming approximately 230 dairies in 2006, the 

average additional cost per dairy would be over $15,000 per year. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 28 June 2004 August 2004

As noted in the above section, the cost-effectiveness of a digester where the recovery of 

electricity costs is roughly comparable to the cost-effectiveness of a fabric in-vessel 

composting system. However, staff could not choose to require the use of digesters in 

PR1127. The reasons have to do with the technical and economic nature of dairying in the 

South Coast. First, consider the technical nature of dairying in the South Coast. In areas 

where free-stall barns are used, in particular those with flushed lane systems, manure can 

more easily be removed, even on a daily basis. Typically, the manure-laden water from 

such dairies ends up in a waste lagoon on-site. In this situation, retrofitting the lagoon to 

capture emissions (e.g. a cover) and then venting them to a generator or control equipment 

is possible. Unlike dairies in other parts of the country, dairies in the South Coast are 

predominantly dry lot corrals. To make use of the current digester, dairies must spend extra 

money to vacuum up manure from their feedlanes daily to send it to the digester. This extra 

equipment and labor add to the cost of using a digester for a dry-lot corral dairy. Also, only 

about 30% of the total manure on the dairy can be captured this way. The remaining 

manure is deposited in the corral and must be cleared and processed in more traditional 

ways. For the digester scenario considered in the incremental cost-effectiveness section 

above, the annualized cost for a digester would be between $930,000 to $1,490,000 to 

process the manure from approximately 22 dairies. If the cost was imposed solely on the 

dairies, the cost would be $42,000 to $68,000 per dairy per year. The capital cost alone 

would be $370,000 per dairy. 

Alternatively, consider the annualized costs to digest the same amount of manure that is 

currently composted (e.g., 226,400 tons/year). The cost to for the fabric in-vessel system 

would be $4.1 million per year. The annualized cost for a sufficient number of digesters ( 

~8 new digesters of the capacity of the current IEUA digester) would be $7.7 million (with 

electricity cost recovery) to $12.3 million (with no electricity cost recovery) per year. The 

capital cost for that many digesters would be approximately $67 million. With the 

relocation of the dairies, a key issue is guaranteed feedstock for any facility with high 

capital costs. The fabric in-vessel systems are more scalable to variations in feedstock 

throughputs, since they have lower initial capital costs and the machinery is movable. 

Second, consider the economics of the local dairy industry. As noted in the draft PR1127 

Socioeconomic Report, over the last few year, milk production costs have exceeded the 

“mailbox” price that producers would get for their milk. In addition, many dairymen either 

lease their lands or are contemplating moving within the next two to five years. In this 

situation, fewer dairymen could recover the capital costs of building and operating a 

digester. Fabric in-vessel composting systems are scalable; fewer could be operated in later 

years when fewer dairies will result in less manure to be processed. Increased compliance 

costs to the dairy farms that would need to be absorbed by the dairy sector can not currently 

be passed down to consumers due to the milk pricing structure in California. Public/private 

partnerships between public service utilities and the dairy operators could overcome many 

of the economic barriers to the use of digesters. Public utilities could more easily use the 

energy produced by the digester for their round-the-clock operations, and thus recover some 

costs through energy savings. Also, the potential exists to design these digesters for 

multiple feedstocks, allowing the transition from manure to wastewater treatment. Staff does 

not, however, recommend that local utilities be required to build and operate digesters for 

dairy manure. Thus, although staff supports the use of digester technology, it believes that 

the cost impacts coupled with the cost recovery uncertainties are too severe at the present 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 29 June 2004 August 2004

time to require their use by local dairies as the sole compliant technology because of the 

special technical and economic nature of the local dairies. However, a milk pricing 

structure that allowed individual dairies to better recover control costs and/or availability of 

public or private grant funding could certainly help overcome these obstacles. Staff is 

committed to continue to work with the local dairy industry and others toward that goal. 

CALIFORNIA ENVIRONMENTAL QUALITY ACT 

Pursuant to the California Environmental Quality Act (CEQA) and SCAQMD Rule110, the 

SCAQMD has prepared CEQA documents to analyze any potential adverse environmental 

impacts associated with the proposed rule. In November 2002, an initial version of PR 1127 

was released to the public along with a preliminary evaluation of environmental impacts 

from implementing the proposed rule. This initial evaluation identified air quality and 

transportation/traffic as potential adverse significant impacts. As a result, a Notice of 

Preparation (NOP) of a Draft EA for PR 1127, including the Initial Study (IS), was prepared 

and distributed to responsible agencies and interested parties for a 30-day review and 

comment period from November 1, 2002, to December 3, 2002. Potential adverse impacts to 

other environmental areas were not identified in the IS. Two comment letters were received 

regarding the environmental analysis in the NOP/IS during the 30-day public review and 

comment period. However, since the release of the NOP/IS, the project description has 

changed. Under the new project description, the potential environmental impacts will not be 

significant and, therefore, an NOP/IS is not necessary. The comment letters on the 

previously released NOP/IS were not responded to or included in the Draft EA. The EA is a 

substitute document prepared pursuant to §15252. Alternatives were not identified and 

evaluated because review of the project showed that the project would not have any 

significant or potentially significant effects on the environment (CEQA Guidelines 

§15252(b)(2)). In accordance with CEQA Guidelines §15105(b), the Draft EA with no 

significant impacts was be circulated for public review and comment for 30 days from March 

30, 2004 to April 28, 2004. No comment letters were received that directly commented on 

CEQA issues. 

SOCIOECONOMIC ASSESSMENT 

The socioeconomic assessment for the proposed rule has been prepared and is released as a 

separate document. 

OUTREACH AND PUBLIC COMMENTS 

PR1127 has been in extensive rule development since 2000, beginning with a public 

workshop in October 2000. A PR1127 Working Group was formed and has met 9 times 

since March 2001. A public consultation meeting was held in April 2002. The Preliminary 

Draft Staff report was released in November 2002 and another public workshop was 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 30 June 2004 August 2004

conducted on November 21, 2002. In addition to the one oral comment, staff received six 

written comments specific to the PR1127 Preliminary Draft Staff report or the NOP/IS. 

In response to public comment on the November PR1127 proposal, staff further investigated 

various digester technologies and their costs, tracked SB700 development and 

implementation requirements as they pertain to PR1127, and began researching alternative 

composting technologies. In January 2004, staff released a revised PR1127 proposal, based 

on staff’s analysis of previous comments. Staff received comments on the proposal at the 

February 2004 PR1127 Working Group meeting. On March 30, 2004, staff released the draft 

Environmental Assessment (EA) for PR1127. As part of the draft PR1127 EA, staff released 

proposed rule language, dated March 26, 2004. Subsequent to the release of the draft 

PR1127 EA, staff held a public workshop on April 22, 2004 to take public comment on the 

March 26th proposed rule language. Staff has received several oral and written comments 

stakeholder meetings and the public workshop, and written comments subsequent to the 

public workshop. 

The first section contains responses to comment received on PR1127 since the release of the 

revised PR1127 proposal in January 2004. Response to comments received before 2004, 

including comments on the November 2002 Preliminary Draft Staff Report can be found in 

the next section. Responses to comments on PR1127 received after staff released the revised 

PR1127 proposal in January 2004 are included in the section following the next section. 

Response to Comments Received Before 2004

A summary of the oral and written comments on the November 2002 PR1127 proposal that 

were received before January 2004 is provided below, followed by staff responses. (If a 

comment was received both before and after January 2004, the response to comment will be 

made in the Response to Comments Received After January 2004 section.) 

Comment 1: Clarify the meaning stockpiles, as used in Tables 4 and 5 of the PR1127 

Preliminary Draft Staff Report, and describe how the baseline emissions are determined. 

Staff Response: On-dairy stockpiles are included in the per-cow emission factors. Before 

the 1999 water quality regulations, most of these on-dairy piles were ultimately (within one 

or two years on average) land spread, mostly in the Basin, or were stored in large semipermanent stockpiles, generally off-dairy. These off-dairy, semi-permanent stockpiles were 

eliminated by 2002 in response to water quality regulations. Total raw manure emissions are 

based on the cow population multiplied by the appropriate emission factor, and in the years 

up through 2001, emissions from the off-dairy stockpiles. For 2002 and later years, raw 

manure baseline emissions are based solely on cow population multiplied by the appropriate 

emission factor. 

Comment 2: Explain why a VOC emission factor of 16 lbs/head/year is used rather 

than the CARB factor of 12.8 lbs/head/year. 

Staff Response: Based on further communication and clarification from CARB, staff is 

using the CARB-recommended 12.8 lbs/head/year VOC emission factor in this staff report. 

Comment 3: Nutrition strategies (e.g. less nitrogen in the feed) could result in 

immediate 10 to 50% reduction in excreted nitrogen. Why isn’t this option listed in PR 

1127? 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 31 June 2004 August 2004

Staff Response: This issue was extensively discussed in PR1127 Working Group 

meetings. Although nutrition strategies may have emission reduction potential, the technical 

database is small, information is widely variable, and key issues, such as representativeness, 

have not been resolved (TetraTech, 2002). A current AQMD contract study with UC Davis 

was initiated, in part, to establish a test protocol(s) for determining the effectiveness of 

nutrition studies, as well as manure treatments. In addition, the impact on cow health, milk 

production, water quality, and other cross-media impacts have not been fully assessed at this 

time. AQMD staff will continue to review scientific studies on nutrition strategies, but does 

not believe that the emission reduction effectiveness and other impacts of these strategies is 

sufficiently known to include in PR 1127 at this time.

Comment 4: What is the link between PR1127 and the water quality regulations (e.g. 

SARWQCB Order No. 99-11)? Why doesn’t PR1127 require compliance with the water 

quality regulations? 

Staff Response: Certain control actions may both improve air and water quality. For 

example, SARWQCB Order No. 99-11 requires the twice-yearly removal of manure 

stockpiles to prevent groundwater contamination and PR1127 requires four-times-per-year 

removal to reduce the time the raw manure can emit emissions to the air. In this case, 

PR1127 goes beyond the water quality requirements to achieve additional airborne 

emissions. For compliance purposes, PR1127 contains certain recordkeeping and reporting 

requirements that are also required by the SARWQCB. Other water quality regulations, such 

as flood control retention ponds, are for water quality purposes only. Thus, PR1127 does not 

require compliance with the water quality regulations as a whole, since certain water quality 

requirements do not impact air quality and others may not be sufficient to achieve more 

emission reductions. However, PR1127 does require compliance with certain water quality 

regulation requirements (e.g. stockpile removal, recordkeeping, and reporting), where 

appropriate to achieve the air quality objectives. 

Comment 5: Does an anaerobic digester require an AQMD permit? 

Staff Response: Yes. Any new digester must comply with the requirements of Regulation 

II – Permits and Regulation XIII – New Source Review, including Rule 1303 Best Available 

Control Technology (BACT) requirements. For example, the current pilot plant digesters 

established by the IEUA are permitted by the AQMD. 

Comment 6: The definition of a controlled composting facility is not consistent with 

the requirements of PR 1133.2. 

Staff Response: At the time of the original draft rule PR1127, the Rule 1133 series of 

composting rules had not been adopted. With the adoption of Rules 1133, 1133.1, and 

1133.2, references to controlled composting operations have been removed from PR1127 and 

direct references to Rule 1133.2, in particular, have been added. 

Comment 7: How do ammonia emissions contribute to PM10? 

Staff Response: The link between ammonia emissions and ammonia aerosol PM10 (e.g. 

ammonium nitrate and ammonium sulfate) is incorporated into the air modeling conducted 

by the District as part of its attainment demonstration. In brief, the highly concentrated dairy 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 32 June 2004 August 2004

areas in the central Basin (Chino/Ontario area) are downwind of the major sources of NOx 

and SOx located in the western (coastal) Basin. NOx and SOx react, in part, to gaseous nitric 

and sulfuric acids. These acids are advected over the dairy areas. Under the right conditions, 

ammonia from the concentrated dairies can react with the gaseous acids to form aerosol 

PM10 in the peak PM10 areas directly downwind of the dairies. The conditions most 

conducive to aerosol formation include moister days with lower inversions; these days are 

most frequent in the fall and early winter. A fuller description of the ambient PM10 

modeling (including aerosol concentrations), inventory, and aerosol modeling (including 

aerosol chemistry) can be found in the 2003 AQMP, Appendix V, Chapter 2.

Comment 8: Other controls (e.g. manure treatments) or control technologies (e.g., 

pyrolysis) may prove to be effective. How can they be included in the rule’s control options? 

Staff Response: The control option assessment (TetraTech, 2002) describes a number of 

controls and control technologies that may prove effective. Although certain options are not 

sufficiently quantifiable to include as rule control options, AQMD staff realizes that future 

scientific and technical work may address these uncertainties. For example, certain manure 

treatments and nutrition strategies may prove effective in reducing VOC and/or ammonia 

emissions. The AQMD is supporting a contract study to identify and develop test protocols 

for manure treatments. This contract study will not be finished until the fall of 2004; 

subsequent studies would be necessary to set certification limits for the manure treatments 

using the testing protocol. In the interim, PR1127 includes a provision that allows the use of 

alternative control options that demonstrates equivalent emission reductions. Such 

alternatives would have to be approved by AQMD, CARB, and U.S. EPA.

Comment 9: Moving manure from the Basin to the San Joaquin Valley and other areas 

will increase emissions in those areas. The rule should discourage out-of-Basin manure 

transport to ozone and/or PM10 non-attainment areas. 

Staff Response: Staff has removed the previous rule proposal language that set a 

percentage disposal requirement that could have encouraged further transport of manure out 

of the Basin. In the current rule proposal, an additional manure disposal alternative is 

identified (e.g. alternative manure processing operations) that is cost-competitive with 

disposal alternatives such as shipping out of the Basin. Basin manure is currently used to 

fertilize crops in the San Joaquin Valley (about 20% of Basin manure goes out the Basin, 

mostly to the San Joaquin Valley) and staff analysis does not indicate that PR1127 will 

significantly change the amount of disposal out of the Basin. There are legitimate uses for 

manure outside of the Basin. Staff believes that PR1127 is neutral in relation to out-of-Basin 

spreading. PR1127 does contain reporting provisions that will allow the calculation of outof-Basin manure transport in subsequent years. 

Response to Comments Received After January 2004

A summary of the oral and written comments received since January 2004 is provided below, 

followed by staff responses. 

Comment 1: PR1127 reporting and recordkeeping requirements should be as consistent 

as possible with water quality control board requirements. PR1127 should not reference 

specific water quality regulations since the water quality board is in the process of revising 

current regulations. AQMD and water quality board staff should work together to streamline 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 33 June 2004 August 2004

reporting requirements to minimize the impact of duplicative paperwork on farmers. 

Industry representative also requested consolidated reporting. 

Staff Response: AQMD staff has revised PR1127 to improve consistency with water 

quality control board reporting and recordkeeping requirements. PR1127 has also been 

revised to reference water quality regulations in general. AQMD staff proposes to work with 

water quality board staff to prepare joint reporting forms, where possible. 

Comment 2: Industry has specific concerns about PR1127 BMPs. The option limiting 

scraping to before 9am is unnecessary if the manure is sufficiently moist as to reduce fugitive 

dust emissions. Second, the scrapping part of the manure removal equipment is designed not 

to dig into the manure hardpan, consistent with the proposed rule language. However, the 

“blade” level is not set, per se. Concerning the removal frequency, weather, crop land 

availability, service provider availability, and backhaul issues limit the industry’s ability to 

ensure four removals per year. In particular, corrals cannot be cleared of rain-laden manure 

without damaging the manure hardpan that serves as both bedding for the cows and a barrier 

to the percolation of salts into the ground. Manure can only be sent to crop land during 

certain times after harvesting and before planting. Requiring manure removal when crop 

land is not available would increase costs, since land application is the lowest-cost disposal 

alternative. Only a few legitimate haulers (fully licensed by the DMV and CHP) currently 

exist, and they may not be able to accommodate the increased demand by the additional 

required removals. Lastly, at farms that backhaul manure in trucks that bring in feed, 

stockpiles are cleared on a truck-by-truck basis, not on one specific day, as implied in the 

draft rule language. 

Staff Response: AQMD staff has revised the proposed rule language in response to some 

of these comments. Requirements for corral clearing and stockpile removal have been split 

into two separate paragraphs. The proposed rule still requires clearing and removal 4 times 

per year, but acknowledges that corral clearing and stockpile removal may occur at different 

times. In recognition that corrals cannot be cleared without damage to the manure hardpan if 

the manure is too wet, an exemption provision for one clearing per year (and its related 

stockpile removal) has been added. The exemption is based on moisture monitoring in the 

corrals, with required reporting, recordkeeping, and exemption request provisions. It is 

staff’s understanding that if in-corral stockpiles have been created, they can be cleared even 

if wet. Based on that information, no exemption for stockpile removal has been created, if 

the stockpile has been created. Staff has addressed the concern that the phased removal of 

stockpiles (which occurs at most farms and especially at farms that backhaul manure using 

feed trucks) separation of corral clearing and stockpile removal requirements and changing 

the proposed rule language to focus on the date of final clearing/removal (as opposed to the 

beginning of the process). At this time, staff has not received conclusive information 

concerning hauling limitations due to crop land availability and hauler availability to warrant 

additional proposed rule changes. 

Comment 3: Future relocation rates will probably be higher than 2%/year. For 

example, much of the Riverside County dairy area of the Chino Basin has been developed or 

is in escrow. Will staff re-evaluate the relocation rate and how could this affect rule 

development or implementation? 

Staff Response: In response to information from Milk Producers’ Council in a 

memorandum dated April 15, 2004, staff has prepared an alternative future analysis (see 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 34 June 2004 August 2004

above) to assess the impact of accelerated dairy relocation. Although accelerated relocation 

further reduces VOC and ammonia emissions in future years, staff believes that additional 

reductions from PR1127 are necessary and desirable to comply with SB700 and to make 

expeditious progress toward attaining the ozone and PM10 standards. 

Comment 4: PR1127 does not meet the goal of emission reduction equity among all 

sources in the District. For example, Rule 1133.2 imposed expensive control requirements 

on biosolids composting operations. Also, staff has not maximized the emission reductions 

from this source. For example, PR1127 fails to capture and control emissions that occur 

immediately (within three days) after it has been produced by the cow. 

Staff Response: PR1127 breaks important new air quality regulation ground. As noted in 

the background section, no previous criteria air pollution regulations for dairies or other 

livestock operations have been enacted anywhere. Unlike many AQMD source-specific 

rules, it establishes requirements on the whole facility (e.g. farm), instead of setting emission 

control requirements for specific pieces of equipment or specific processing operations as in 

other rules. PR1127 establishes best available control measures (BACM) on a whole facility 

to reduce PM10, VOCs, and ammonia, as well as setting requirements on where material sent 

from the facility is used or processed. (Traditionally, BACM is expressed as the Best 

Management Practices (BMPs) for agricultural sources). This is consistent with other 

BACM rules on existing area sources, such as Rule 403 and 1186. To control emissions that 

occur before the corral can be cleared would require the complete re-design and re-building 

of the current dairies to free-stall and/or flushed lane configurations. The costs for such a redesign and re-building would be prohibitive. 

New dairies can be designed and built to capture and control emissions from fresh manure in 

a much quicker manner. AQMD Regulation XIII contains New Source Review requirements 

for all new and modified permit units. Under SB700, new dairies are subject to permits, 

Regulation XIII and applicable BACT. 

Comment 5: Some comments stated that emission reductions from certain digester and 

composting technologies may exceed current standards and that PR1127 should set the 

standards that would provide incentives these technologies. One comment suggested that 

PR1127 establish uniform manure and emission baseline and reduction standards. Other 

comments have expressed concerns that PR1127 does not set new performance standards for 

manure processing technologies (e.g. digesters, composters), as was done in Rule 1133.2 for 

composting operations, for example. 

Staff Response: As noted in the air quality regulations background section, PR1127 is 

designed to fulfill only certain SB700 requirements, e.g. BACM for dairy facilities. Title V 

and other local permitting for equipment at dairies, as well as other confined feeding 

operations and crop farms, is underway. AQMD staff will also be conducting a review of its 

current BARCT (Best Available Retrofit Control Technology) rules that had exemptions for 

agricultural sources, as well as developing facility permits for certain confined animal farms. 

Staff does not agree that PR1127 limits manure processing technologies, as it does not 

prevent the BACT review of new digester and composting–related technologies. The 

AQMD will also be applying Regulation XIII, New Source Review, to new confined animal 

farms, such as new dairies. It is in the application of BACT standards through existing 

Regulation XIII requirements that these comments are best addressed. BACT determinations 

for manure processing technologies will be done in the same manner as BACT determination 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 35 June 2004 August 2004

for other emission sources. As such, AQMD rule staff has forwarded these comments and 

supporting material describing specific manure disposal technologies to the AQMD’s 

Technology Advancement Office, where BACT reviews are conducted. AQMD rule staff 

has also forwarded the Proposed Preliminary Draft BACT Requirements for New and 

Expanding Dairies in development by the San Joaquin Unified Air Pollution Control District 

to the BACT-review staff. AQMD staff recognizes concerns that the previous version of 

PR1127 may limit new technologies by too strictly identifying the sources within the dairy 

subject to BACT. In response, staff has removed the new dairy language from PR1127 and 

will rely on the existing Regulation XIII process to identify and require BACT, as is done 

with all other sources. 

Some of the comments imply that PR1127 should set one emission standard for manure 

processing operations as a whole, as opposed to the current AQMD practice of establishing 

standards for each type of operation, i.e. composting operations and digesters. Although 

both types of operations process manure (or biosolids or greenwaste), they are not designed 

for the same results. A digester is designed to maximize methane emissions, while a 

composter is designed to produce a specific type and quality of compost. Indeed, digester 

digestate may need to be further composted and/or blended to be used in certain applications. 

Thus, AQMD staff does not concur that a general emission standard should be set for manure 

processing operations. It should be noted that composters (of any type) can comply with 

PR1127 manure processing operation approval requirements by meeting the standards in 

Rule 1133.2 and digesters (of any type) can comply with PR1127 manure processing 

operation approval requirements by meeting the standards of the applicable AQMD permits 

(Regulations II and XIII). 

The largest current open-windrow manure composting operations will no longer accept 

manure beginning in 2006. Sufficient digesters do not exist to handle the anticipated amount 

of manure, nor are any scheduled to be built. Based on staff analysis, we conclude that no 

new digesters or Rule 1133.2-compliant composters will be built for manure processing 

unless subsidized; so far we cannot identify any such sufficient available funding. Without 

in-Basin manure processing operations capable of handling the throughput at existing openwindrow composting facilities, farmers will maximize in-Basin landspreading (which has the 

least emission reduction potential), increase out-of-Basin manure transport (which would 

significantly increase diesel truck emissions due to lengthy haul trips), increase out-ofDistrict emissions, or worst-case, potentially resort to illegal dumping (no emission 

reductions). PR1127 was designed to address these concerns and provide additional 

incentive for the development of new composting technologies. Staff does concur that 

previous versions of PR1127 do not sufficiently provide incentives for optimizing alternative 

manure composting operations. Staff has revised PR1127 to require PR1133.2-type source 

testing for these facilities and will prepare resolution language requiring staff to report back 

to the Governing Board on the control effectiveness of existing alternative manure 

composting operations and the potential for additional control (and emission reductions) 

from these sources. 

Comment 6: Wasterwater agencies are frequently subject to AQMD enforcement 

actions against odors. The composting rule staff report detailed the odor complaint history 

associated with that source. In contrast, the PR1127 Preliminary Draft Staff Report contains 

only a brief reference to odors. Why are the dairy odors and odor nuisance being treated so 

differently by the AQMD? 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 36 June 2004 August 2004

Staff Response: The difference originates in state law. Health and Safety Code Section 

41705(a) specifically says that Section 41705 nuisance provisions shall not apply to odors 

emanating from agricultural operations. This language is repeated in AQMD Rule 402, 

Nuisance. Although AQMD is prohibited from issuing nuisance complaints from 

agricultural sources, PR1127 should reduce emissions of certain odorants, such as ammonia 

and certain VOCs. 

Comment 7: PR1127 should apply BACT under Regulation XIII to new and modified 

farms subsequent to the effective date under SB700, not January 1, 2005. Also, the entire 

dairy should be subject to BACT and BARCT; PR1127 only applies BACT to storage 

lagoons. Similarly PR1127 applies BARCT to corrals, feedlanes and manure disposal 

activities, and it should apply BARCT to all emission sources at the dairies. Lastly, PR1127 

must apply the BACT requirements to new and modified dairies upon adoption. 

Staff Response: To address these comments, staff has removed the requirements for new 

and modified dairies from PR1127. Any new and modified dairies will be addressed by the 

AQMD’s existing Regulation XIII – New Source Review, including Regulation XIII’s 

BACT provisions. Concerning BARCT, PR1127 applies BARCT to fugitive emission 

sources such as corrals, feedlanes and manure disposal activities. As part of its overall plan 

to implement SB700, the AQMD is conducting a review of all of its BARCT rules containing 

agricultural exemptions. As part of that review, AQMD staff will evaluate and determine, 

consistent with SB700 requirements, standards and emission limits that should apply to 

equipment at agricultural operations. Once CARB establishes the definition of “large 

CAFs,” AQMD staff will re-visit BARCT for all emission sources on the dairy as it develops 

the “large CAF” emission reduction permit regulation that must be adopted by July 1, 2006, 

as required by SB700. As noted above, any new or modified dairies will be subject to 

Regulation XIII, independent of the adoption date of PR1127. See also response to 

Comment #5 in this section. 

Comment 8: New digester and manure management technologies, such as those 

presented by BION Dairy Corporation and Organic Power USA, Inc., could reduce dairy 

manure emissions to a great extent. PR1127 should: 1) create a uniform standard for 

release of methane and ammonia without reference to a specific technology; 2) establish a 

uniform baseline that is consistently applied across all applications; 3) set uniform boundary 

conditions from cradle to grave for the animal waste for application of the established 

baseline standards; 4) set uniform definitions for manure minimal percent solids, and 

allowable percent of inert materials, bedding and feed wastes; and 5) evaluate all BACT 

technology according to the same baseline and uniform standards as they impact overall 

emissions from dairies. The goal should be to create a level playing field for competing 

technologies, similar to Rule 1133.2. Technology design, analysis and testing information 

was also provided. 

Staff Response: The most appropriate way to evaluate new dairy manure management 

technologies is through BACT analysis conducted for new source review. AQMD’s existing 

Regulation XIII – New Source Review includes BACT requirements for new and modified 

facilities. Under SB700, new and modified dairies would be subject to New Source Review. 

The information and comments provided by technology providers has been forwarded to the 

AQMD’s Technology Advancement Office for BACT review. (The San Joaquin Valley Air 

Pollution Control District (SJVAPCD) is also doing a BACT review for dairy-related 

technologies. The Proposed Preliminary Draft BACT For New And Expanding Dairies and 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 37 June 2004 August 2004

related documents can be found on the SJVAPCD web site: www.valleyair.org under the 

link for “New Requirements for Agricultural Operations.”) In Rule 1133.2, the AQMD 

staff set baseline and controlled emission standards for a single process. Existing dairies 

consist of several different process areas that can be quite different (or even not exist) on 

individual dairies. Regardless, the level playing field that you are suggesting is already 

embedded in our process of establishing BACT standards. Specifically, the BACT standards 

are established based on the technology that results in the lowest emission rates for a given 

process. Alternative technologies that can demonstrate equivalent emission reduction 

benefits are also allowed as BACT-equivalent. These comments have been forwarded to the 

Technology Advancement Office staff for their consideration during BACT review. See also 

response to Comment #5 in this section. 

Comment 9: Air emissions from landfills are not addressed in either Rule 1133.2, 

PR1127, or any other known rule. This creates an unfair situation in that the beneficial uses 

of organic materials through composting or digestion are regulated while landfilling these 

organics is not regulated. 

Staff Response: Air emissions from landfills are regulated by AQMD Rule 1150 – 

Excavation of Landfill Sites (adopted October 1982) and Rule 1150.1 – Control of Gaseous 

Emissions from Municipal Solid Waste Landfills (adopted April 1985, amended April 1998 

and March 2000). Also, any new or modified landfill would be subject Regulation XIII – 

New Source Review. 

Comment 10: AQMD should seek emission reductions beyond those that will occur 

from relocation. The rule should set performance standards for alternative manure 

composting operations and digesters. AQMD should set a “preferable” manure processing 

option to maximize emission reductions. Energy recovery costs should be accounted for in 

assessing digester impacts. We agree that the best management practices should go beyond 

the current water quality regulations (e.g. more frequent corral clearing and stockpile 

removal). Lastly, the compliance threshold for new dairies should be reduced to the 50 cow 

per dairy limit for exemption for existing dairies and that existing dairies that are 

significantly modified, including through increased herd size, should be subject to enhanced 

controls. 

Staff Response: AQMD staff concurs that PR1127 should seek reductions beyond those 

occurring from relocation. In reference to performance standards for alternative manure 

composting operations, please see the response to Comment #5 in this section. Any new or 

modified digesters are subject to Regulation XIII – New Source Review and its BACT 

analysis. Manure is a beneficial fertilizer and soil amendment. AQMD staff received many 

adverse comments on earlier rule proposals that mandated the use of certain options for a set 

amount of manure. Restricting legal land spreading could impact crop farming operations 

and could encourage the use of chemical fertilizers. As to setting a rule preference between 

composting operations and digesters, please see the response to Comment #5. Staff has 

included energy recovery costs in its digester analysis (see the Incremental CostEffectiveness section). As noted in previous response to comments, requirements for new 

and modified dairies will be addressed through existing AQMD Regulation XIII – New 

Source Review. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 38 June 2004 August 2004

Response to Comments Received On The June 4, 2004 Draft Staff 

Report

A summary of the additional written comments received on the June 4, 2004 Draft Staff 

Report is provided below, followed by staff responses. 

Comment 11: AQMD should attempt to standardize the definitions of greenwaste or 

green materials between the various environmental rules and regulations, which would be 

critical to the elimination of illegal and/or misguided activities. PR1127 should use the 

definition of green materials from the California Code of Regulations Title 14, Section 

17852, which limits contamination of the green material to less than 1.0 percent by weight.

Staff Response: Staff concurs. The green waste definition has been replaced by the 

definition of green materials from the California Code of Regulations Title 14, Section 

17852.

Comment 12: If PR1127 is adopted, staff should hold Rule 1127 implementation workshops 

for the dairy farmers, similar to the workshops held by the San Joaquin Valley APCD for 

their Rule 4550.

Staff Response: Staff concurs. The implementation workshop, which would be scheduled 

prior to the December 1, 2005 implementation date, would cover registration and annual 

reporting requirements, notification procedures, moisture testing protocols/reporting, and 

other implementation topics.

Comment 13: Dairy farmers remain concerned about the technical barriers and economic 

impact of requiring 4, rather than 2, stockpile removals per year. For farmers who haul 

manure away using trucks that bring in feed, it takes more than the 1 month specified in the 

proposed rule to completely remove the stockpile. For farmers sending their manure to local 

crops, the planting schedule is such that the fields are typically only available twice per year 

for spreading and dairy farmers have timed their stockpile removal to match the crop cycles. 

It would involve significantly more cost to the dairy farmer and the crop farmer if the manure 

had to be processed (e.g. composted) rather than left in on-dairy stockpiles until the crop 

fields are ready.

Staff Response: Although most of the crop land available for spreading is in the San Jacinto 

watershed, manure comes from dairies in the Chino (28% of total manure) and the San 

Jacinto (14% of total manure) areas. Concerning the local crop cycles, manure would still be 

available for direct land spreading, although it may come from a greater number of dairies 

removing their 3-month accumulations. Dairies that traditionally sent manure to local crops 

on a twice a year schedule, may need to send some of their manure to a processing operation. 

(The least-cost processing operation would be a fabric in-vessel operation relatively close to 

the dairies). Other dairies would now have the lower-cost option of sending additional 

manure from their farms to cropland. Overall, there would be no net impact, although some 

dairies would see higher costs and others would see lower cost. With the relatively small 

facility footprints and lower infrastructure requirements for alternative manure composters, it 

is possible to site them closer to the dairies that would need them. However, to minimize 

the impact to dairy farmers, staff is proposing to extend the time period for completely 

removing the stockpile from 1 month to 3 months from the last clearing. The emission 

reductions are maintained since stockpiles are still removed 4 time per year (no less than 60 

days between removals). In addition, although manure stockpiles still emit due to biologic 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 39 June 2004 August 2004

activity, they are not subject to active re-wetting by urinating cows, which increases 

emissions. Lastly, notification requirements for corral clearing and stockpile removal have 

been removed since the rule requires adequate recordkeeping and reporting to determine 

compliance.

Comment 14: Industry provided comments on the costs used in the Draft Socioeconomic 

Report. They included direct cost figures for in-Basin shipping, out-of-Basin shipping (with 

and without backhaul), and some questions concerning the costs related to fabric in-vessel 

composting. Please provide additional information on the cost and use of moisture meters.

Staff Response: The costs in the Draft Socioeconomic costs include the direct costs 

mentioned in the comment, but also include the indirect costs that would also be borne by the 

dairy farmers, such as loading, specialized labor, special collection systems for those dairies 

sending manure to the digester, etc. Staff will update the round-trip mileage for in-Basin 

shipping to 80 miles roundtrip, as suggested. As to out-of-Basin shipping, the actual cost 

does indeed depend on distance, with a range of $12/ton to San Joaquin to $16/ton to 

Imperial. Staff used the higher cost for the staff reports to capture the full range of costs. 

PR1127 does not, in itself, impact the final location of the composted material, which has 

been and will be affected by market and other regulatory forces. Any changes would not be 

an impact of PR1127 and thus, is not included in the impact reports. Concerning moisture 

testing equipment, Imperial County APCD staff uses “hay” moisture meters for ICAPCD 

Rule 420 compliance testing (e.g., manure in feed yards between 20 and 40%). The cost of 

the water moisture equipment ranges from $200 to $900. Staff will provide additional 

guidance for manure moisture testing at the implementation workshops (see Response to 

Comment 12). 

Comment 15: In previous versions of PR1127, dairies that sent fresh feedlane manure to 

digesters daily were exempt from more frequent corral clearing and stockpile removal 

requirements. This was because of the significantly greater emission reductions that resulted 

from prompt removal of the fresh manure. (Removing feedlane manure daily accounts for 30 

to as high as 60% of the total corral manure.) Please reinstate the previous exemption from 

more frequent corral clearing / stockpile removal for dairies daily clearing feedlane manure 

to a digester.

Staff Response: Staff concurs and has reinstated the exemption language. Those dairies 

would still be required to remove any on-dairy stockpiles twice a year because of water 

quality regulations.

Comment 16: Given that the mailbox milk price is largely controlled by the California 

Department of Food and Agriculture, the best way to additional emissions reductions from 

this source category at less cost to the farmers would be to educate them as to the benefits of 

credit generation through additional controls paid for by others. As you are aware, local 

industries are desperately in need of cost-unprohibitive PM credits to sustain a healthy 

economy. AQMD staff is familiar with credit generation efforts, successful and otherwise, 

and all the criteria EPA wishes to see for such programs ( identification in the emission 

inventories, surplus issues, SB 700/705 etc.). If the information contained in the PR1127 

staff report is not sufficient to answer all the questions concerning the potential use of these 

types of emission reduction credits, staff should address them separately through postadoption analyses.
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 40 June 2004 August 2004

Staff Response: There are both technical and policy barriers to the actual generation of 

usable emission credits from controlled manure processing. EPA’s credit criteria require that 

the credits be permanent, real, quantifiable, surplus, and enforceable. These criteria have 

traditionally be difficult to meet for area sources (as opposed to point sources). In addition, 

the greatest interest has been in the use of ammonia reductions as PM10 credits. The link 

between ammonia and PM10 is highly non-linear and dependent on the source location in 

reference to NOx and SOx sources, the source concentration, and meteorology. This makes 

it technically difficult to establish a relationship between ammonia reductions and PM10 

reductions. Although PR1127 establishes certain control requirements, these are not BACT 

requirements; emission credits are generally BACT-discounted, which could also limit the 

credit generation potential of many manure processing operations. In the Governing Board 

resolution, staff proposes to do a follow-on assessment of the emission credit generation 

potential of manure processing operations and report back to the Board’s Stationary Source 

committee upon the completion of that study.

Comment 17: Additional cost and other information concerning the BION 

Microaerobic/Anoxic Animal Waste Nutrient Management System (NMS) has been 

provided. The use of digesters in PR1127 depends on the treatment of ammonia-rich liquid 

effluent in existing wastewater treatment facilities, while the BION system can treat the 

effluent on site. The cost benefit of ERCs that the BION system could produce could be very 

valuable if a mechanism existed to realize those benefits. Also, the potential cost benefits of 

the BION system increase with dairy size; although this may not be the situation in South 

Coast, it is a very real consideration for dairies in other areas in California and the nation. 

Please review this information and consider the inclusion of the BION system in PR1127.

Staff Response: Staff has reviewed the additional comment material, and re-iterates its 

responses to comments 5, 8, and 10 above. In addition, staff notes that the BION system 

requires that manure be fluidized and then in the process, the solids are separated out. For 

dairies that use lagoons for waste storage, such as flushed lane systems and certain scrapped 

lane dairies, this is done as part of the dairies general operations. For dry-lot corrals, this 

would require adding dry manure to significant amounts of water, and then separating out the 

solids as part of the BION process. The effect of this is to transfer the ammonia in relatively 

dry and aerobic conditions (SCAQMD emission factor for local dry lot corral dairies = 51 lbs 

ammonia/cow/year) to ammonia in an anaerobic aqueous solution (CARB emission factor for 

flushed lane/lagoon diaries = 74 lbs ammonia/cow/year), and then treating the ammonia. 

This would require re-design and re-building of existing dairies, which is more appropriate 

for new dairy requirements rather than existing source-specific rules, such as PR127. 

PR1127 does not exclude the use of the BION system, but it also allows the treatment of the 

dry manure in controlled processing operations, such as Rule 1133.2 composters. As noted 

in the response to Comment 16, there are technical and policy barriers to realizing the 

emission reduction credit of manure processing technologies such as the BION system, but 

staff is proposing to further assess this subject.

The discharge of anaerobic digester effluent waste water should meet the requirements of the 

National Pollutant Discharge Elimination System (NPDES) for the applicable local water 

quality control board (e.g. SARWQCB). For concentrated animal feeding operations 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 41 June 2004 August 2004

(dairies and related facilities) within the Santa Ana Region, the General Waste Discharge 

Requirement is specified by NPDES Permit CAG018001, RWQCB Order No. 99-11 and, 

dairy facilities, the Engineered Waste Management Plan (EWMP). (NOTE: other areas in 

California do not have NPDES requirements.) All municipal publicly owned treatment 

works (POTWs) in the Santa Ana Watershed Region are required to meet tertiary or 

equivalent water treatment standards except for Orange County Sanitation District which is 

transitioning to full secondary treatment. 

DRAFT FINDINGS AND COMPARATIVE ANALYSIS 

Health and Safety Code Section 40727 requires the AQMD to adopt written findings of 

necessity, authority, clarity, consistency, non-duplication and reference. 

Necessity - State and federal health-based ambient air quality standards for particulate 

matter and ozone are regularly and significantly violated in the AQMD. The reduction of 

ammonia and VOC from PR 1127 is part of a comprehensive strategy to meet federal and 

State air quality standards. 

Authority - The AQMD Board obtains its authority to adopt, amend, or repeal rules and 

regulations from Health & Safety Code Sections 40000, 40001, 40440, 40441, and 40702. 

Clarity - The AQMD Board determines that PR 1127 is written or displayed so that persons 

directly affected by it can easily understand its meaning. 

Consistency - The AQMD Board determines that PR 1127 is in harmony with, and not in 

conflict with or contradictory to, existing federal or State statutes, court decisions, or 

regulations. 

Non-Duplication - PR 1127 does not impose the same requirements as any existing State or 

federal regulation and is necessary and proper to execute the powers and duties granted to, 

and imposed upon, the AQMD. 

Reference - In adopting this proposed rule, the Board references the following statutes 

which the AQMD hereby implements, interprets or makes specific: H&S Code Sections 

40001 (rules to achieve ambient air quality standards) and 40440(a) (rules to carry out 

AQMP). 

Incremental Cost-Effectiveness Assessment - Health and Safety Code Section 40920.6 

requires an assessment of incremental cost effectiveness for proposed regulations relative to 

ozone, CO, SOx, NOx, and their precursors. Incremental cost effectiveness is defined as the 

difference in control costs divided by the difference in emission reductions between the most 

stringent option compared with the next less costly control option. This staff report contains 

an incremental cost-effectiveness assessment, as required. 

Comparative Analysis 

Health and Safety Code §40727.2 requires a written analysis comparing the proposed rule 

with existing regulations. Table 11 identifies other AQMD rules that apply to the equipment 

and sources subject to PR 1127. Except for the Rule 1133 and 1133.2, none of these rules 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 42 June 2004 August 2004

applies to the same “source type”, i.e., dairy manure, as Rule 1127, so §40727.2 does not 

require a more detailed analysis of the requirements of these rules. Footnotes explain the 

differences between PR 1127 and the other AQMD rules where relevant. As required by 

Health and Safety Code § 40727.2, the purpose of this analysis is to identify and compare 

any other AQMD or federal regulations that apply to the same operations or source type. 

Currently, staff has not identified existing federal regulations or AQMD requirements that 

apply to dairy operations with regard to VOC and ammonia emissions. Imperial County Air 

Pollution Control District Rule 301 420 requires that feedlot manure be kept between 20 and 

40% moisture levels to reduce fugitive PM10 emissions. On May 20, 2004, the San Joaquin 

Valley Unified Air Pollution Control District (SJVUAPCD) considered the adoption of 

Proposed Rule 4550, Conservation Management Practices, which requires PM10 BMPs for 

agricultural operations, including dairies. PR1127 PM10 BMPs are a subset of SJVUAPCD 

PR4550 PM10 BMPs for dairies. Other federal, state and local requirements not directly 

associated with air emissions have been summarized in the Background and Legal Authority 

section. 

TABLE 13 

Comparison Of PR 1127 And Other AQMD Rules 

203 Equipment that may cause the 

issuance of air contaminants 

Requires that air pollution sources 

comply with permit conditions 

402 Any source except 

agricultural odors 

Prohibits public nuisance caused by 

emissions of air contaminants 

Rule Equipment/Source Analysis 

112 Applies to all equipment or 

activities emitting air 

pollutants 

Defines a minor violation and sets 

guidelines for issuance of a notice to 

comply 

201 Equipment that may cause the 

issuance of air contaminants 

Requires that air pollution sources obtain 

Permits to Construct 

202 Equipment that may cause the 

issuance of air contaminants 

Requires that air pollution sources obtain 

Permits to Operate 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 43 June 2004 August 2004

TABLE 13 (continued) 

Comparison Of PR 1127 And Other AQMD Rules 

 

2

 Dairies can only send manure to composting operations that are Rule 1127 approved, per subdivision (f). One of 

the approval requirements is that the composting operation be registered as required in Rule 1133. 3

 Dairies can only send manure to composting operations that are Rule 1127 approved, per subdivision (f). A 

composting operations that is in compliance with Rule 1133.2 subdivision (d) and is registered as required in Rule 

1133, is a Rule 1127 approvable manure processing operation. PR1127 requires no additional requirements on 

Rule1133.2-compliant facilities, except registration as a Rule 1127-approved manure processing operation. PR1127 

does exempt alternative manure composting operations from the provisions (e.g., operating parameters, work 

practice requirements, emission limits, and recordkeeping and reporting requirements) of Rule 1133.2, except for 

the Rule 1133.2 testing provisions, if and only if the alternative manure composting operation complies with the 

PR1127 requirements, including the work practice and operating parameter requirements in paragraph (e)(3). 4

 Rule 1186 represents primary PM10 BACM for unpaved roads and travel areas at dairies. PR1127 represents 

primary PM10 BACM for corral sources. Together, they represent BACM for dairy fugitive dust sources. 

5

 Regulation XIII requires New Source Review for all new and modified permit units. All new and modified 

digesters have permit units that would be subject Regulation XIII. Permit units at new and modified composting 

operations would also be subject to Regulation XIII. SB700 requires permits for new and modified dairies, thus 

they would also be subject Regulation XIII. 

Rule Equipment/Source Analysis 

1133 Composting and 

chipping/grinding operations 

Administrative requirements for 

composting and chipping/grinding 

operations2

1133.1 Chipping / grinding 

operations 

Requirements to prevent the inadvertent 

decomposition during chipping and 

grinding activities 

1133.2 Co-composting operations Requires controls or equivalent 

emission-reduction practices to reduce 

VOC and ammonia at operations that 

compost biosolids and/or manure3

1186 Paved and unpaved roads, 

livestock operations (dairies) 

Requires the treatment of unpaved 

access connections and feed lane access 

areas, and the cessation of grain grinding 

activities in certain conditions4

Reg. XIII 

New Source 

Review 

(NSR) 

All new and modified permit 

units 

NSR requirements include BACT, 

modeling, emission offsets, sensitive 

zone requirements, facility compliance, 

and major polluting facility requirements 

such as alternative analysis, statewide 

compliance, protection of visibility, and 

compliance through CEQA5
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 44 June 2004 August 2004

REFERENCES 

Abt Associate, Inc., Apelberg, B, McCubbin, D., Divita, F., Roe, S., Air Quality Impacts of 

Livestock Waste, September 2000. 

ATC, M.C. Chitjian, M. Koizumi, C.W. Botsford, G. Mansell and E. Winegar, Final 1997 

Gridded Ammonia Emission Inventory Update for the South Coast Air Basin, August 2000. 

California Regional Water Quality Control Board Santa Ana Region, Fact Sheet, General Waste 

Discharge Requirements for Concentrated Animal Feeding Operations (Dairies and Related 

Facilities) within the Santa Ana Region, Order No. 99-11, NPDES No. CAG018001, August 

1999. 

California Regional Water Quality Control Board Santa Ana Region, Results of 2002 Annual 

Waste Discharge Analysis, May 2003. 

City of Chino, The Preserve, Chino Sphere of Influence – Subarea 2, Draft Environmental 

Impact Report, SCH # 2000121036, September 2001. 

Earsom, Jame,. Chino Basin Work With Dairies, Soil and Water Conservation Society and 

Southern California Coalition of Resource Conservation Districts’ Regional Workshop, 

September 1996. 

Environmental Protection Agency, Results of the Measurement of Volatile Organic Compounds 

(VOCs) from Livestock Waste, January 1995. 

Inland Empire Utilities Agency, Chino Basin Organics Management Strategy Business Plan, 

May 2001. 

National Research Council, The Scientific Basis for Estimating Air Emissions From Animal 

Feeding Operations Interim Report, 2002. 

NC State University, Dairy Production Newsletter, April 1999. 

Radian, R.J. Dikson, Development of the Ammonia Emission Inventory for the Southern 

California Air Quality Study, September 1991. 

Riverside County, California, Ordinance No. 427.3, An Ordinance of the County of Riverside 

Regulating The Land Application of Manure, April 2001. 

Ritzman, E.G., and Benedict, F.G., Nutritional physiology of the adult Ruminant. Carnegie Inst. 

Washington, 1938. 

Schmidt, C.E., Ph.D, Winegar, E., Ph.D. Final Technical Report Results of the Measurements of 

PM10 Precursor Compounds (PM10PCs) From Dairy Industry Livestock Waste, June 1996. 

Splansky, J. A, Geography of Dairying in the Los Angeles Basin: Past and Present, Fall 2000. 
DraftFinal Staff Report Proposed Rule 1127 

PR 1127 45 June 2004 August 2004

Santa Ana Watershed Project Authority's GIS and Database Management Services.

San Joaquin Valley Air Pollution Control District, Preliminary Draft Report, Best Available 

Control Technology (BACT), Dairy Operations, April 2004 

Taback, H. et al. Control of Hydrocarbon Emissions From Stationary Sources in the California 

South Coast Air Basin, October 1984. 

Tetra Tech Inc., Egigian-Nichols, Task 1 - Survey Current Livestock Waste Management 

Practices in the South Coast Air Basin, January 2002. 

Tetra Tech, Inc., Egigian-Nichols, Task 2 – Literature Survey and National Programs, Livestock 

Waste Management Practices Survey and Control Option Assessment, Draft Report, May 2002. 

Tetra Tech Inc., Egigian-Nichols, Task 3 – Identify Potential Waste Management Practices 

Reducing Ammonia and VOCs, Livestock Waste Management Practices Survey and Control 

Option Assessment, Preliminary Draft Report, November 2002. 

United Nations, Economic Commission for Europe, Convention on Long-Range Transboundary 

Air Pollution, Working Group on Technology, Report on Abatement Techniques to Reduce 

Ammonia Emissions from Agricultural Livestock, January 1996. 
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PR 1127 A- 1 June 2004August 2004

APPENDIX A –CONTROL OPTIONS

Work completed by the AQMD Livestock Waste Working Group as well as reports on the 

Survey of Livestock Waste Management Practices and emission factor studies that have been 

completed by SCAQMD contractors have aided in developing the following analysis of 

potential control options. 

Best Management Practices 

California SB 700 is one of a package of air quality bills sponsored by senator Dean Florez 

to remove the exemption for agricultural sources from regulatory requirements and requires, 

by July 1, 2006, that each Air Quality Management District or Air Pollution Control District, 

which is designated as a “serious” non-attainment area for various types of particulate matter 

to adopt an implement best available control measures for agricultural stationary sources of 

air pollution. 

The following BMPs are proposed to reduce PM10 emissions and increase the emission 

reduction effectiveness of certain manure processing requirements. 

i) The following manure harvesting protocols can be used to minimize fugitive dust 

(PM10) emissions: 

(1) Scrape or harrow in early morning (before 9am) when moisture is higher and 

winds are low. 

(2) Set blade level such that an even surface of compacted manure remains on top of 

the soil (e.g., do not scrape down to soil level). Pulling, rather than pushing, 

blades are recommended. 

(3) Sprinkle corral before manure harvesting to reduce dust through increased surface 

moisture (This measure is not recommended for lactating cows). 

ii) Minimize water in corrals (e.g. better drainage, eliminate water leaks). 

iii) Feedlanes must be paved at least 8’ on the corral side of the fence. 

iv) Clear corrals and any on-dairy stockpiles 4 times per year, with one time being 

between October 1 and November 30. 

v) Fugitive dust BMPs for feed processing and unpaved roads/surfaces have already 

been implemented in Rule 1186. 

Stock Pile Elimination / Reduction 

In this control option, the dairy operator removes manure stockpiles more frequently than is 

currently practiced or prevents stockpiles altogether. Manure stockpiles on dairies have been 

a common practice. Data indicates that manure stockpiles are a significant ammonia source, 
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on the average about 10% of the total ammonia emitted from a dairy. The Santa Ana 

Regional Water Quality Board (SARWQCB) in 1999 adopted ordinances regulating manure 

management and stockpile removal. Since that time, dairies under compliance orders have 

removed manure stockpiles and cleaned their corrals of manure at least twice annually. 

Estimates indicate that 100% of the ammonia and VOC emissions would be controlled 

yielding a reliable net removal effectiveness for the dairy of about 10%. 

The ease of implementation of this control option is relatively high. There are no capital 

facilities required on the part of the dairy. There exists a vibrant community of service 

contractors specializing in manure management services to the dairy industry that are 

providing all of the needed services for this option. The time scale for implementation for 

this alternative is immediate. 

Regulatory program implementation related to this alternative is significant. Current state, 

SARWQCB, manure management requirements require manure stockpile cleanup and 

removal by the end of 2003. In areas without strong water quality requirements, air quality 

agencies may also implement similar regulations. 

Manure Harvesting / More Frequent Corral Cleaning 

In this control option, the dairy operator removes manure and urine more frequently than is 

currently practiced. The animal excretes the majority of its nitrogen in its urea. This nitrogen 

hydrolyzes rapidly into ammonia gas. To the extent that the manure and urine can be 

removed quickly for additional treatment, the ammonia and VOC emissions will be less. The 

open area of the corral is estimated to contribute an average of 61% of the overall ammonia 

emissions in dry lot dairy farms in southern California. Removal of the manure twice a year 

is estimated control up to 50% of the ammonia and VOC emissions. This results in a net 

removal effectiveness of VOC and NH3 for the dairy of about 30% for corral cleaning twice 

yearly. Implementation of requirement to clean the corral more frequently will increase the 

removal effectiveness. 

The ease of implementation of this control option is relatively good. There are no capital 

facilities required on the part of the dairy. Depending on the size of the dairy and the ultimate 

disposition of the manure solids, operators may need to acquire additional rolling stock that 

could include a tractor, collection machinery, hauling trailers, or land application equipment. 

Additionally, the operator may need to evaluate personnel requirements for implementation 

of this option. Alternatively, there exists a vibrant community of service contractors 

specializing in manure management services to the dairy industry that can immediately 

provide all of the needed services. 

The time scale for implementation of this control option is immediate. There are no ramp up 

time requirements associated with this option. Regulatory program implementation related 

to this alternative is insignificant. Current state and federal manure management 

requirements call for manure cleanup and removal at least once every six-months. No 

additional other regulatory requirements are imminent that would affect the dairy operator’s 
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manure management program. The cost-effectiveness of this control measure is estimated to 

be reasonable. The practices required to achieve the option’s goals are achievable with only 

minor adjustments and a small cost increase. The implementability of this control measure is 

estimated to be high. 

Land Application of Manure 

In this control option, the dairy operator removes manure for land application to cropland as 

a fertilizer. Land application as a control measure can be effective. The practice should 

follow Natural Resources Conservation Service Conservation Practice Standard # 633- 

Waste Utilization. Estimates indicate that up to 50% of the ammonia and VOC emissions 

could be controlled yielding a net removal effectiveness for the dairy of about 22% when 

accomplished within the air basin. As commercial fertilizer has reduced the need for manure, 

the economic benefit of manure has been increasingly viewed only in terms of the direct 

benefit associated with the essential nutrients for crop growth. This typically is measured in 

terms of the fertilizer replacement value. For example, an application of 10 tons of solid beef 

manure to an acre of land reduces fertilizer nitrogen requirements by about 40 lbs. during the 

next cropping year, which would save the farmer about $10 per acre at present fertilizer 

prices, disregarding the cost of manure application. Utilization of manure applied to land is 

accomplished through microbial conversion of plant residues and wastes into usable crop 

nutrients. Breakdown of organic nutrient sources takes considerable time with only a fraction 

of the applied nitrogen being available the first year. Actual mineralization rates are difficult 

to determine given the fact that this is a biological process that is sensitive to temperature 

and moisture conditions found in the soil system. In manure, nitrogen is mostly organic and 

ammonium nitrogen. Organic nitrogen is a slow release nitrogen source. Ammonium N is 

equivalent to commercial fertilizer and, except for that lost to the air, can be used by plants in 

the application year. Organic nitrogen must be converted to inorganic form before plants can 

use it. Variable amounts of organic nitrogen are released to the soil in a plant-available form 

during the first cropping year after application. Organic N released during the second, third, 

and fourth cropping years after initial application is usually about 50%, 25%, and 12.5%, 

respectively of that mineralized during the first cropping season (MWPS, 1985). 

• Methods of application of manure are: 

o broadcast (top dressed) with plow-down or disking, broadcast without plow-down 

or disking, 

o knifed (wet manure injected under the soil surface), and irrigated (liquid manure). 

The greatest nitrogen response follows land application and immediate incorporation into the 

soil. Best management practices recommend to plow down solid manure as soon as possible 

to minimize nitrogen loss and to begin release of nutrients for plant use. Most losses occur in 

the first 24 hours after application, so the most air quality benefit occurs when manure is 

incorporated into the soil as soon as possible. Injecting, chiseling, or knifing liquids into the 

soil minimizes odors and nutrient losses to the air and/or to runoff. Nitrogen loss as ammonia 

from land is greater during dry, warm, windy days than during humid or cold days. Ammonia 

loss is generally greater during the spring and summer months. Use of manure should be 

based on at least one analysis of the material during the time it is to be used. In the case of 
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daily spreading, the waste should be sampled and analyzed at least once each year. As a 

minimum, the manure analysis should identify nutrient and specific ion concentrations. 

Where manures are to be spread on land not owned or controlled by the producer, the manure 

plan, as a minimum, should document the amount of manure to be transferred and who will 

be responsible for the environmentally acceptable use of the manure. Additional description 

of the practice includes: 

 All manure should be utilized in a manner that minimizes the opportunity for 

contamination of surface and ground water supplies. 

 Where manures are utilized to provide fertility for crop, forage, fiber production, and 

forest products, the practice standard Natural Resources Conservation Service, 

Conservation Practice Standard, Nutrient Management (Code 590) should be 

followed. 

 Manures should be applied at rates not to exceed the crop nutrient requirements or 

salt concentrations as stated above, and should be applied at times the manures can be 

incorporated by appropriate means into the soil within 72 hours of application. 

 The effect of Waste Utilization on the water budget should be considered, particularly 

where a shallow ground water table is present or in areas prone to runoff. Limit 

manure to the volume of liquid that can be stored in the root zone. 

 Minimize the impact of odors of land-applied manures by making application at times 

when temperatures are cool and when wind direction is away from neighbors. Priority 

areas for land application of manures should be on gentle slopes located as far as 

possible from waterways. 

 When manures are applied on more sloping land or land adjacent to waterways, other 

conservation practices should be installed to reduce the potential for offsite transport 

of manure. 

 It is preferable to apply manure on pastures and hayland soon after cutting or grazing 

before re-growth has occurred. Reduce nitrogen volatilization losses associated with 

the land application of manure by incorporation within 24 hours. 

 Minimize environmental impact of land-applied manure by limiting the quantity of 

manure applied to the rates determined using the practice standard Natural Resources 

Conservation Service, Conservation Practice Standard, Nutrient Management (Code 

590) for all waste utilization. The manure management plan is to account for the 

utilization or other disposal of all animal wastes produced, and all manure application 

areas shall be clearly indicated on a plan map. The operation and maintenance plan 

should include the dates of periodic inspections and maintenance of equipment and 

facilities used in manure utilization. The plan should include what is to be inspected 

or maintained, and a general time frame for making necessary repairs. 

The ease of implementation of this control option is good. Land application of manure using 

best management practices is currently required by state and federal laws and regulations. 

Compliance enforcement measures are underway by the SARWQCB. The time scale for 

implementation for this alternative is immediate. The status of regulatory program 

implementation related to this alternative is significant. Current state and federal manure 
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management requirements call for manure cleanup and removal at least once every sixmonths. Certain county ordinances regulate how manure is incorporated into cropland. 

Open Aerated Static Pile 

In this control option, the dairy operator removes manure and urine to ASP composting 

facilities within the Southern California Air Basin. As detailed in the previous section, 

composting via aerated static pile, emissions from composting operations can be greatly 

reduced. The size of the source relative to manure management is a function of the timing of 

manure removal from the dairy. The source size for relatively dry corral manure is about 

60% while fresh or daily removal could approach 100%. ASP composting, where suction air 

is used, the air is typically captured and discharged through a biofilter for removal of odor, 

ammonia, and volatile organic compounds. 

The ease of implementation of this control option is good. Composting at windrow types of 

facilities is underway and has been practiced by the dairy industry for many years. 

Implementation of ASP or enclosed ASP facilities is underway in several locations in 

Southern California. The time scale for implementation for this alternative is immediate and 

sustained. Rule 1133 regarding composting facilities was recently adopted by the AQMD. 

This rule moves the hierarchy of composting to ASP or enclosed ASP and away from 

windrow facilities. 

Inland Empire Utilities Agency (IEUA) has developed a new totally enclosed ASP 

composting facility in Rancho Cucamonga. This facility will replace the existing cocomposting facility on Chino California. The enclosed facility will primarily process 

biosolids and a small amount of manure. 

Open Windrow 

In this control option, the dairy operator removes manure and urine to open windrow 

composting facilities within the Southern California Air Basin. Windrow composting 

emissions do not result in any reduction of ammonia or VOC’s. This method of composting 

may add ammonia and VOC burden to the air basin. The results of this feasibility assessment 

indicate that windrow composting does not result in emissions reductions and may aggravate 

emissions issues. 

Rule 1133 regarding composting facilities was recently adopted by the AQMD. This rule 

moves the hierarchy of composting to ASP or enclosed ASP and away from windrow 

facilities. 
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Fabric In-Vessel or Covered Aerated Static-Pile 

With the upcoming closure of existing co-composting facilities, there has been an increased 

interest in enclosed aerated static pile technology, such as fabric in-vessel (FIVs), for the 

organics. FIVs use the aerobic composting process as co-composting facilities to 

decompose organic materials. However, the FIV aerated method of composting manure 

would take place in an elongated plastic container or bag (see Figure 1-4), typically 10 feet 

in diameter and 200 feet long, which would act as a containment cell with forced aeration. 

FIGURE 1-4 

Fabric In-Vessel (Composting Bag) 

The typical process would involve the collection of the manure before it is placed into a 

hopper where the manure is mixed, ground, and possibly adjusted for the proper carbon 

nitrogen ratio. Hoppers are designed for forklift handling, can be dumped safely from any 

height and are precisely balanced to tip foreward for complete discharge of contents and 

return to an upright position. Attached to the hopper is a hydraulic ram which is used to 

push the manure material through the filling chamber and compact into the plastic container 

or bag (see Figure 1-5). Compaction is essential to maintain porosity. Pushing the 

hydraulic ram forward and leaving it extended against the material will effectively leave the 

product sealed for aeration purposes. Retracting the ram leaves the hopper ready for another 

load. 

FIGURE 1-5 

Hopper Filling the Fabric In-Vessel 
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After the manure is packed into the container and sealed, the aeration pipe is attached to a 

timer controlled electric air blower that maintains aerobic conditions. Optimum 

temperature and moisture conditions are maintained by managing the blower operating time 

and the venting water vapor during the composing process. Each containment vessel holds 

approximately 200 tons of manure. It typically takes 10-14 weeks for the manure to 

compost. 

Covered Aerated Static-Pile system by the controlled use of a PTFE membrane that is 

permeable to oxygen but impermeable to large molecules. In addition to the membrane, 

which covers the organic material during composting, the system includes a concrete floor 

and wall, blowers for aeration, and a winder for efficient movement of the cover. The 

system also requires consistent management including preparation of materials to achieve a 

homogenous mixture with moisture content of 55-60 percent and monitoring of temperature 

and oxygen levels. With this system, the composting process takes eight weeks. The 

“heap” of organic material is covered by the membrane, which is secured to the ground, 

allowed to compost for four weeks, then moved and re-covered for two weeks for 

stabilization. During the final two weeks of curing, the heap is uncover 

Use of Anaerobic Digesters for Disposal of Dairy Waste 

Anaerobic digestion (AD) is the microbial decomposition of an organic matter by 

microorganisms in the absence of oxygen to produce a stabilized biomass and “biogas”, 

consisting of methane (CH4), carbon dioxide (CO2) and trace gases. The stabilized biomass 

(the digestate) can be separated into fiber and liquid. The fiber can be used and sold as a soil 

amendment. The biogas can be burned in a boiler or furnace or used to produce electricity. 

The liquid is rich in nutrients and can be used as a substitute for inorganic fertilizer. 

 

Technology 

AD occurs in four stages: 

1. The organic plant or animal matter (proteins, carbohydrates and lipids) is 

decomposed (hydrolyzed) to soluble compounds such as sugar. The hydrolysis of 

the organic matter is the rate limiting step. 

2. The soluble compounds are fermented to short chain, volatile fatty acids. 

3. Acetogenesis forms hydrogen, CO2 and acetate. 

4. Methanogenesis converts the fatty acids to biogas (methane). 

The acid forming bacteria are tolerant to environmental changes such as pH and 

temperature. In contrast, the methane forming bacteria are intolerant to environmental 

changes. The anaerobic digestion process is outlined in the following flow diagram. 
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 Figure 1: Anaerobic Digestion Process 

Types of Digesters: 

The types of anaerobic digesters include Covered Lagoon, Batch Digester, Plug-Flow 

Digester, Completely Stirred Tank Reactor (CSTR), Upflow Anaerobic Sludge Blanket 

(UASB), and Anaerobic Sequencing Batch Reactor (ASBR), and others. The complete-mix, 

plug-flow, and the covered anaerobic lagoon are three types of the digesters that are 

recognized by the USDA's Natural Resource Conservation Service (NRCS) in the form of 

"National Guidance provided to States." The different digester designs, all trap methane and 

reduce fecal coliform bacteria, but they differ in cost, climate suitability, and the 

concentration of manure solids that type of digester can digest. 

Important factors, such as temperature, moisture and nutrient contents, and pH are also 

critical for the success of AD. AD can be best occurred at three range of temperatures, 

psychrophilic (5-15 °C), mesophilic (30-40°C) and thermophilic (50-60°C). In general, AD 

at mesophilic temperature is more common even though digestion at thermophilic 

temperature has the advantages of reducing reaction time, which corresponding to the 

reduction of digester volume. Psychrophilic digesters are used in colder climate areas. 

Moisture contents in greater than 85% or higher are suitable for AD. 

The complete-mix digester is a large, vertical poured concrete or steel circular container. 

The manure is deliberately mixed within the digester reactor. The mixing process creates a 

homogeneous substrate that prevents the formation of a surface crust and keeps the solids in 

suspension. Today's complete-mix digester can handle organic wastes with total solid 

concentration of 3% to 10%. Mixing and heating improves the digester efficiency. 

Complete-mix digesters can be operated at either the mesophilic or thermophilic 

temperature range with a hydraulic retention time (HRT) as brief as 10-20 days. 
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The basic plug-flow digester design is a long linear chamber, often built below ground level, 

with an air-tight expandable cover. Organic wastes is collected daily and added to one end 

of the trough. Each day a new "plug" of organic wastes is added, slowly pushing the other 

manure down the trough. Plug-flow digesters are usually operated with a total solid 

concentration of 11%-13% at the mesophilic temperature range, with a HRT from 20-30 

days. A mixing pit is used to prepare the manure for use in the digester. The manure total 

solids concentration is adjusted by dilution with water to a range of 11% - 13% in a mixing 

pit prior to the digestion process. 

A cover lagoon is an earthen lagoon fitted with a floating, impermeable cover that collects 

biogas as it is produced from the organic wastes. The cover is constructed of an industrial 

fabric that rests on solid floats laid on the surface of the lagoon. The cover can be placed 

over the entire lagoon or over the part that produces the most methane. An anaerobic lagoon 

is best suited for organic wastes with a total solid concentration of 0.5%-3%. Cover lagoons 

are not heated. 

Covered lagoon digester operation and maintenance is simple and straightforward compared 

to complete-mix and plug-flow digesters. The capital cost for covered lagoon can be less 

than those required for the complete-mix and plug-flow types of conventional digesters. 

However, a key issue for covered lagoon is that digestion is dependent on temperature, 

therefore biogas production varies seasonally if the lagoon is not externally heated. This 

means that methane production is greater in summer than in winter. In general, a daily 

biogas production in summer could be averaged 35% higher than in winter. This may make 

end-use applications more problematic than plug flow and completed mix digesters. Another 

concern is that it can take an anaerobic lagoon as long as 1-2 years to achieve its "steady 

state" biogas production potential. 

Anaerobic Digestion in the Chino Basin 

The Inland Empire Utilities Agency (IEUA) is a municipal water district in the Chino Basin. 

The IEUA supplies imported drinking water and recycled water, collect, treat and dispose of 

wastewater, and provides utility-related services in the Chino Basin. IEUA implemented an 

Organics Management Strategy program to protect the Chino Groundwater Basin from 

infiltration of salts, nutrients and pathogens generated by dairies to reduce future costs of 

removing contaminants from the groundwater. 

The IEUA has developed two manure digestion demonstration projects. The IEUA 

digesters are centralized facilities and odeled after the Danish, community and CAD 

designs. The digesters serve a small cluster of 14 dairies for a total of 16,000 cows. Fresh 

manure is removed daily from the corral and transported to the digestion facilities. The 

treatment process consists of an anaerobic digester for the destruction of organic material 

and the production of methane gas used to provide 0.75 MW of power used to supply a 

portion of the power requirements of IEUA facilities. The biosolids produced by digestion 

are dewatered and conveyed to a composting facility, while the filtrate is discharged to the 

sewer line. 
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The two digesters are located at IEUA’s Regional Plant No.1 (RP-1) and Regional Plant 

No.5 (RP-5) in the Chino Basin. The digester at RP1 is a complete mix digester and was 

built by retrofitting an existing digester used for municipal waste. IEUA plans to use this 

digester to co-digest manure and municipal waste. The RP-1 complete mix digester is a 

public-private partnership with the dairy industry to digest approximately 150 wet tons per 

day of manure. IEUA initially operated RP-1 in phase 1 which is the digestion of manure 

only. A second phase, Phase II, will be the digestion of manure and biosolids. RP-1 

digester pilot project is similar in design to the Danish CAD system with potential to digest 

manure and municipal biosolids as well as supply biogas and/or electricity to the facility. 

The initial goals of the RP-1 Pilot Project were to 

: 

• Demonstrate use of a complete mix thermophilic anaerobic digester technology to 

process a mixture of biosolids and manure. 

• Supply biogas to provide additional fuel for the electric generator at RP-1 

• Generate 0.25 MW of power 

• Produce 30 tons per day of organic fertilizer 

• Remove over 5 tons per day of salts/nitrates from groundwater in Santa Ana River 

Watershed 

 

The digester at RP-5 is a plug flow digester designed specifically to process dairy manure. 

The plant includes feedstock mixing and heating tanks, plug flow anaerobic digester and a 

belt press and centrifuge for dewatering the digestate. RP-5 will digest 225 wet tons per day 

of fresh manure at 12-20% solids from 3,750 cow. IEUA is currently optimizing the process 

parameters (feedstock and operating temperature) in an effort to optimize the methane 

production and characteristics of the digestate. IEUA is assessing the use of food waste 

from the food industry (brewery and cheese) to augment the digester feedstock. RP-5 

digester plant is similar to the European community digester plants since it accepts manure 

from local dairy operations. The electrical generated by micro-turbines is used to run a desalter operated by IEUA in the Chino Basin. The initial goals of the RP-5 pilot project were 

to: 

• Demonstrate plug flow anaerobic digestion technology 

• Supply 210,000 cu ft/day of biogas as fuel to the gas-fired generators at the 

Chino-I Desalter. 

• Generate 0.5 MW of power 

• Produce 135 tons/day of organic fertilizer 

• Prevent 4 tons/day of salts/nitrates from entering Chino Groundwater Basin 

watershed 

• Develop practical methods for collecting and transporting fresh manure from 

dairy feed lots 

Both of the digester pilot projects have been successful and IEUA has plans to expand the 

RP-5 facility and to incorporate technology modifications. 
 APPENDIX B 

PR1127-1 

PROPOSED RULE 1127 EMISSION REDUCTIONS FROM LIVESTOCK WASTE 

To reduce the bulk of the rule package and avoid repetition, please refer to the latest 

version of Proposed Rule 1127, which is located in Attachment F of this rule package.