Rule 217 Staff Report

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IMPERIAL COUNTY AIR POLLUTION CONTROL DISTRICT

STAFF REPORT

For the Proposed Revisions to Amended 

Rule 217 – Large Confined Animal Facilities (LCAF) Permits Required 

RULE 202 - Exemptions

RULE 101 - Definitions 

I BACKGROUND 

The Imperial County is currently designated as a nonattainment area for the 

federal ozone, PM10 and PM2.5 standards. The Imperial County Air Pollution 

Control (Air District) maintains the responsibility of regulating air pollution from all 

sources within the County of Imperial. As required under state law, the Air 

District adopts rules to achieve ambient air quality standards and enforces the 

provisions of local, state, and federal air quality laws. 

On December 2, 2014, the Air District adopted the Imperial County 2013 PM2.5

State Implementation Plan for the PM2.5 Nonattainment (NA) demonstrating that 

Imperial County is in attainment “but-for” emissions from Mexico and as such 

ammonia emissions do not need to be reduced to address PM2.5 standard. 

However, to improve the public health and further reduce VOC and ammonia 

emissions to prepare for the new annual PM2.5 NAAQS, the Air District committed 

to the United States Environmental Protection Agency (U.S. EPA) to examine the 

potential role of ammonia within the Imperial County PM2.5 NA. The Air District

has identified three main sources of ammonia emissions.

• Confined Animal Facilities (Air District Rule 217)

• Composting Facilities (Permitted Facilities)

• Agricultural Fertilizers

To address emissions from Confined Animal Facilities, on October 10, 2006, the 

Air District adopted the current version of Rule 217, Large Confined Animal 

Facilities (LCAF) Permits Required. Rule 217 was adopted in response to 

legislative enactment of Senate Bill 700 (SB700) – Florez – Agricultural Sources. 

The purpose of Rule 217 is to limit emissions of VOC’s and ammonia from Large 

Confined Animal Facilities (LCAF). This Rule applies to facilities operations that 

are corralled, penned, or otherwise restricted to areas of defined dimension and 

are fed by means other than grazing. Such facilities include, but are not limited 

to, cattle, calves, chickens, ducks, goats, horses, sheep, swine, rabbits, and 

turkeys. The Imperial County mainly has 2 types of facilities: Beef Operations 

and Dairy Operations. 
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The Air District proposes to amend Rule 217 to further reduce Volatile Organic 

Compound (VOCs) and Ammonia emissions to improve public health and to 

prepare for the annual PM2.5 NAAQS which will require the Air District to develop 

a new PM2.5 SIP. The proposed amendment to this rule would strengthen the 

current rule requirements, lower threshold limits, and tighten mitigation 

measures. In addition, clarifying and compliance language was added including 

monitoring, testing, and recordkeeping sections to improve enforcement of the 

rule. 

In addition, the threshold for LCAF’s has been revised to reflect the threshold 

proposed by the San Joaquin’s Rule 4570 and with direction of the U.S. EPA and 

California Air Resources Board (CARB). Therefore, the Air District is also 

amending Rule 101 – Definitions and Rule 202 – Exemptions to reflect the 

revised thresholds where applicable.

The Air District has been working closely with U.S. EPA - Region IX and CARB 

representatives to address any deficiencies in the proposed Rule. The proposed 

rule contains required elements that would improve the rule and assist with 

meeting federal requirements. 

The proposed revision is expected to have a net positive environmental impact, 

and no significant adverse economic impacts. The proposed revision also 

complies with restrictions imposed by California law that prohibit the Air District 

from adopting changes to certain rules that make them less stringent.

II REASON FOR RULE AMENDMENT

Air monitoring data in Imperial County indicates high levels of PM2.5 that exceeds 

the PM2.5 National Ambient Air Quality Standard (NAAQS). As a result, the U.S. 

EPA classified a portion of Imperial County as “moderate” nonattainment for 

PM2.5. Nonattainment areas are required by the Federal Clean Air Act to develop 

State Implementation Plans (SIP) to achieve attainment of the National Ambient 

Air Quality Standards (NAAQS) and protect public health and welfare. Table 2 

identifies the number of days over the Federal PM2.5 Standard. 

Table 2, Number of Days over the Federal PM2.5 Standards.

Year Calculated Number of 

Days over the Federal 

PM2.5 Standard

2014 2

2013 1

2012 4

2011 6

2010 2
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On December 2, 2014, Air District adopted the 2013 SIP for the 2006 24-hr PM2.5

Moderate Nonattainment Area (2006 24-hr PM2.5 SIP). The Air District PM2.5 SIP 

is comprised of regulatory measures to reduce emissions of VOC and Ammonia

which are precursors of PM2.5. The proposed amendments to Rule 217 are 

intended to support the attainment goals of the Air District 2013 24-hr PM2.5 SIP. 

The proposed amendments are intended to reduce VOC and Ammonia from 

LCAFs “as expeditiously as practicable”. 

To address VOC and Ammonia Emissions, on October 10, 2006, the Air District 

adopted Rule 217 – Large Confined Animal Facilities. The purpose of the Rule 

217 is to limit emissions of VOC’s and ammonia from Large Confined Animal 

Facilities (LCAF). This Rule applies to facilities operations that are corralled, 

penned, or otherwise restricted to areas of defined dimension and are fed by 

means other than grazing. Such facilities include, but are not limited to cattle, 

calves, chickens, ducks, goats, horses, sheep, swine, rabbits, and turkeys. The 

Imperial County mainly has 2 types of facilities: Beef Operations and Dairy 

Operations. After adoption by our Air Board, Rule 217 was submitted to U.S. 

EPA to be included into the Imperial County SIP; however, the U.S. EPA and 

CARB identified some deficiencies in this rule and recommended to withdraw 

and revised this rule with an enhanced version which can meet SIP approval. On 

May 3, 2013, the Air District requested the withdrawal of Rule 217 from SIP 

submittal.

Amending Rule 217 will enhance reductions of VOC and ammonia emissions,

which is an important control measure for the Annual PM2.5 SIP. Therefore, the 

Air District proposes to revise Rule 217, to further reduce Volatile Organic 

Compound (VOCs) and Ammonia emissions. The Air District will submit the 

revised Rule 217 to be included into the Imperial County’s SIP. The U.S. EPA 

has recommended that the proposed Rule 217 be revised following San Joaquin 

CAFs Rule. 

Amendments to Rule 101 Definitions

Due to the thresholds for proposed amended Rule 217 for dairy, chicken, and 

duck being proposed to be decreased, Rule 101 will be amended to be 

consistent the proposed Rule 217 thresholds. The amendment will be in 

particular for the Large Confined Animal Facility (LCAF) definition under Rule 

101. 

Amendments to Rule 202 Exemptions

Similarly to Rule 101, Section E.10 Agricultural Sources, section E.10.b of Rule 

202 will be amended to be consistent with the thresholds for the proposed 

amended Rule 217 for dairy, chicken, and duck. 
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III EMISSIONS AND EMISSION REDUCTION ANALYSIS

VOCs are the principal category of pollutants emitted from Confined Animal 

Facilities (CAFs). Research is continuously being carried-out in order to 

determine and analyze emission factors of VOCs from livestock operations, 

especially in regards to dairies and beef feedlots operations. The VOC emission 

factors from Air District, 11 lbs/head-year for beef feedlots and 13.94 lb/headyear for dairies, were also used to evaluate VOC emissions for the Imperial 

County. The Air District has estimated VOC reductions of 6.9 tons per year for 

dairies and 452.7 tons per year for beef feedlots due to the application and 

enforcement of the control measures proposed in Rule 217 (Appendix A). 

Appendix A thoroughly discusses the emission factors and control efficiency for 

VOC for the proposed Rule 217.

Increases in atmospheric ammonia emissions have been reported in recent 

years in areas of animal agriculture. Ammonia is a common by-product of animal 

waste due to the conversion of feed nitrogen into animal product. Livestock and 

poultry are often fed high-protein feed, which contains surplus nitrogen, to ensure 

that the animals' nutritional requirements are met. Nitrogen that is not 

metabolized into animal protein (i.e., milk, meat, or eggs) is excreted in the urine 

and feces of livestock and poultry where further microbial action releases 

ammonia into the air during manure decomposition. 

Currently, ammonia emissions from animal agriculture are not directly regulated. 

However, in 1997, the U.S. EPA issued national Ambient Air Quality Standards 

(NAAQS) for PM2.5. Because a portion of PM2.5 is derived from ammonia, 

regulations aimed at reducing PM2.5 concentrations and emissions will require 

reductions in ammonia emissions from animal production operations.

Ammonia emissions occur at several different stages of livestock production. 

These emissions vary significantly among farms due to differences in methods of 

collecting, storing, and treating manure. In general, the greatest ammonia 

emissions are associated with land application of manure and housing. 

Significant emissions can also occur from grazing land, if applicable, and manure 

storage. As a result, the amended Rule 217 provides opportunities to reduce 

ammonia emissions from animal operations.

It is estimated that amended Rule 217 should generate reductions of 452.7 tons 

per year of VOC, refer to Table 3. A more detailed summary of the reductions 

may be found in Appendix A. Appendix A summarizes VOC emissions for the 

proposed amended Rule 217.
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Table 3: Summary of Reductions

Pollutant VOC Emissions

Dairy Beef 

Feedlot

Uncontrolled Emissions (tons/day) 0.08 5.39

Controlled Emissions (tons/day) 0.06 4.15

Reductions from Proposed Control 

Requirements (tons/day)

0.02 1.24

Reductions from Proposed Control 

Requirements (tons/year)

6.9 452.7

IV PROPOSED RULE AMENDMENTS:

The proposed rule amendments will strengthen the rule by lowering the threshold 

limits, proposing additional mitigation measures, and add compliance language 

including exemptions, monitoring requirements, administrative requirements, test 

methods, and recordkeeping to improve enforceability. The Air District is 

proposing the rule applicability thresholds shown in Table 5:

Table 5 – LCAF Proposed Thresholds 

During the workshop, stakeholders, which were either owners or operators of 

LCAF’s, mentioned that Feedlots and calf operations in Imperial County feed dry 

grains which does not include silage. Therefore, emissions from the feed from 

feedlot and calf operations are assumed negligible. However, the proposed rule 

amendments include a silage category as precaution should a silage type feed is 

fed to the animals. Where applicable, facilities where silage is fed must comply 

with the silage mitigation measures to ensure that emissions are being 

controlled. 

Large CAF Definition By Livestock Category

Livestock Category Large CAF Definition

Beef Feedlots 3,500 beef cattle

Dairy 500 milking cows

Other Cattle Facility 3,500 calves, heifers, or other cattle 

Poultry Facility

 Chicken 400,000 head

 Duck 400,000 head

 Turkey 100,000 head

Swine Facility 3,000 head

Horses Facility 2,500 head

Sheep and Goat Facilities 15,000 head of sheep, goats, or any combination of the two

Any livestock facility not listed 

above 30,000 head
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The inclusion of the menu options of mitigation measures for the amended Rule 

217, are applicable to LCAFs the day of the adoption of the rule. The proposed 

mitigation measures are more stringent than the current measures in the rule.

The impacts to the owner and operators as well as to the public and the industry 

in general, due to the rulemaking process and the amendments of this rule will be 

minimal. 

A. Beef Feedlots 

• The silage mitigation measures would reduce VOC emissions

through a combination of compaction standards, silage quality, and 

face and pile size management.

• Options require multiple required measures as well as frequent 

monitoring. 

B. Dairies

• The regulatory threshold has been modified from 1,000 milking 

cows to 500 milking cows. 

• The silage mitigation measures would reduce VOC emission 

through a combination of compaction standards, silage quality, and 

face and pile size management.

• Menu options are mandatory for feed and housing mitigation 

measures. 

• Solid manure handling menu are required for dairy LCAFs. 

C. Other Cattle

• The silage mitigation measures would reduce VOC emission 

through a combination of compaction standards, silage quality, and 

face and pile size management.

• Options require multiple required measures as well frequent 

monitoring. 

D. Swine

• Mitigation measures provide potential measures from a mandatory 

list of required measures. 

E. Layer

• Mitigation measures provide potential measures from a mandatory 

list of required measures. 

F. Broiler, Duck, or Turkey

• Mitigation measures provide potential measures from a mandatory 

list of required measures. 

• The regulatory threshold has been modified from 600,000 to 

400,000 for chicken and duck. 

G. Exemptions
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• Except for recordkeeping, LCAFs below the threshold at all times 

are exempt from administrative requirements.

H. Monitoring Requirements

• Monitoring requirements section was included for the enforcement 

purposes of the mitigation measures in the Emission Mitigation 

Plan. 

I. Administrative Requirements

• Detailed requirements were included to the records for each 

mitigation measure, to ensure measures were utilized regularly. 

J. Test Methods

• Test methods section was included to ensure the proper and 

approved method was utilized when testing. 

K. Compliance Determination

• Clarifying language was added to this section. 

L. Recordkeeping

• Clarifying language was added to this section. 

V. CATEGORY BACKGROUND

There are 5 Categories that were either amended or are new to Rule 217. These 

categories are: Beef Cattle, Dairy Cattle, Other Cattle, Swine, and Poultry. Each 

category has a set of mitigation measures from which some are mandatory.

A. BEEF CATTLE FEEDING OPERATIONS

Beef cattle operations include adult beef cattle such as heifers and steers. 

Beef cattle feeding operations is the largest source for Imperial County 

Large Confined animal facilities. Beef operations have approximately

357,888 head count based on 2013 Imperial County Agriculture Crop & 

Livestock Report. Due to the National Beef Company processing facility 

closure, the Imperial County does not boast a slay operation currently. 

B. DAIRY CATTLE OPERATIONS

Dairy Cattle Operations are operations that produce milk or animals for 

facilities that produce milk. The Imperial County has one Dairy operation

(Bullfrog) with a head count of approximately 4,000. The information was 

gathered from the Imperial County Air Pollution Control District source

files. 

C. OTHER CATTLE OPERATIONS
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The “Other Cattle Operations”, captures cattle in Confined Animal 

Facilities that do not fit in the definition of dairy or feedlots operations. For 

instance, heifers and calf ranches fit the definition of Other Cattle 

Operations. Heifers and Calf ranches raise young female diary until the 

cow is mature enough to breed. At this stage she is moved to a dairy for 

breeding. 

D. SWINE OPERATIONS

Swine operations are operations that produce pigs or hogs. The 

production cycle includes the traditional approach from birth to finish hog 

production (all stages from breeding until slaughter). Breeder facilities 

produce pigs from birth and raise the pigs to 40 to 60 pounds. The 

grower/finisher facilities raise the pigs from 60 pounds to market weight of 

250 pounds. Currently there no such operations in Imperial County are 

under permit. 

E. POULTRY OPERATIONS 

Poultry Operations is the raising birds such as chickens, ducks, and 

turkeys for the purpose of farming meat or eggs for the fresh meat market. 

Layer ranches raise chickens for eggs while broiler ranches raise chicken 

for meat. Currently there no such operations in Imperial County are under 

permit. 

VI. PROPOSED RULE 217 STRUCTURE

A. Menu Approach

Rule 217 amendments contain menu options for mitigation measures for each 

category: Beef, Dairy, Other Cattle, Swine, and Poultry. The mitigation 

measures are more stringent than the previous version of Rule 217. Several 

categories have mitigation measures that are mandated for various LCAFs. 

However, the Air District acknowledges that not all facilities operate in the 

same manner due various reasons such as infrastructure, permit conditions, 

soil types, production contracts, and other limitations. Therefore, as

categories have mandated mitigation measures, there are also mitigation 

measures by which owners/operators may choose that provide flexibility to 

the various Imperial County LCAF operations. 

B. Section B – Definitions

In this section, 53 definitions were added for the purpose of this rule. Any 

other definitions not included in this rule are found in the Air District Rule 

101. The purpose of the definitions is for clarity and specification purposes 

for current and new control requirements. 

The definitions include – Aerated Static Pile, Aerobic Digester, Aerobic 

Lagoon, Alternative Mitigation Measures, Anaerobic Treatment, Anaerobic 

Treatment Lagoon, CDFA, Certified Nutritionist, Composting, Corral, Day, 
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Dry Manure/Dry Separated Solids, Dry Rolled Corn, Emission Mitigation 

Plan, Facility, Feed Bunk, Feedlane, Freestall Barn, High Moisture Corn, 

Air District permitted Composting Facility, In-Corral Mounds, Lagoon, 

Large Confined Animal Facilities (LCAF), Licensed Veterinarian, Mature 

Cow, Medium Dairy CAF, Milking Cow, Mitigation Measure, Maximum 

One-Time Capacity, Molt, NRC, NRCS, Phototropic Lagoon, Poultry, 

Poultry Litter, Overall VOC Capture and Control, Oxygen Barrier Film, 

Phase Feeding, Processed Cereal Grain or Processed Corn, Rain Event, 

Separated Solids, Shade Structure, Solid Separators System, Split-Sex 

Feeding Program, Steam-Flaked Cereal Grains, Steam-Flaked Corn, 

Storage Pond, Swine, VOC Control Device, Weatherproof 

Covering/Storage Structure, and Year. 

C. Section C - Requirements

The requirement section includes specification to facility mitigation plans 

and permit requirements. Rule 217 amendments propose the all mitigation 

measures as contained in the permit applications must be implemented 

the day operations at a LCAF commence. In addition, Emission Mitigation 

Plans must be submitted by owner/operators of a non diary, beef feedlot, 

swine, or poultry operations which demonstrate facility wide reductions or 

an Emission Mitigation Plan that adheres to requirements of a Facility 

Emission Mitigation Plan found in section C.5. 

D. Section D - Exemptions

The exemption section is for facilities meeting the definition of exemptions 

which remain below the regulatory thresholds at all times. However, 

owner/operators will still need to comply with Administrative Requirements 

found in section F of the rule. 

E. Section E - Monitoring Requirements 

Owners/Operators shall comply with the requirements of Lagoon

Monitoring if applicable. 

F. Section F - Administrative Requirements 

This section provides details for the Administrative Requirements for each 

mitigation measure category. Records must be maintained on a quarterly 

basis. Examples of records that are permitted are records for the purpose 

of animal inventories maintained for financial purposes and the 

Cattlemen’s Association Records, and Water Board records. 

G. Section G -Test Methods 

This section provides the certified and approved versions of test methods. 

H. Section H - Compliance Determination

Language was included to clarify the need of permits renewals and or 

updates. 
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I. Section I - Annual Renewal Permits

No changes were proposed to this section.

J. Section J - Recordkeeping

Clarifying language in recordkeeping information was included to this 

section. 

K. Section K - Public Review

Clarifying language was included in this section. 

L. Section L - Non-duplication

No changes were proposed to this section.

M. Section M - Other Provisions

No changes were proposed to this section. 

Feedlot Mitigation Measures

Summary of Feedlot Mitigation Measures

Area Amended Rule 

Feed Requires implementation of 2 measures from the 

4 practices.

Silage Requires implementation of 1 measure from the 3

practices. 

Housing Requires implementation of 4 mandatory 

measures plus 1 additional practice from the 7 

practices. 

Solid Manure Requires implementation of 1 measure from the 2 

practices. 

Liquid Manure Requires implementation of 1 measure from the 5 

practices.

Land Application Requires implementation of 2 measures from the 

2 practices.

Total 12 of 23

Dairy CAF Mitigation Measures

Summary of Dairy Mitigation Measures

Area Amended Rule 

Feed Requires Implementation of 4 mandatory 

measures plus 1 additional practice from the 8 

practices.

Silage Requires implementation of 1 measure from the 3

practices. 

Milking Parlor Requires implementation of 1 measure from the 2 

practices.

Freestall Barn Requires Implementation of 2 mandatory 
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measures plus 1 additional practice from the 6 

practices. 

Corrals Requires Implementation of 6 mandatory 

measures plus 1 additional from the 10 practices.

Solid Manure Requires Implementation of 1 measure from the 3

practices.

Liquid Manure Requires Implementation of 1 measure from the 5 

practices.

Land Application Requires Implementation of 2 measures from the 

2 practices.

Total 21 of 39

Other Cattle Mitigation Measures

Summary of Other Cattle Mitigation Measures

Area Amended Rule 

Feed Requires Implementation of 2 measures from the

4 practices.

Silage Requires implementation of 1 measure from the 3 

practices. 

Freestall Barn Requires Implementation of 2 mandatory 

measures plus 1 additional practice from the 5 

practices. 

Corrals Requires Implementation of 5 mandatory 

measures plus 1 additional from the 9 practices.

Solid Manure Requires Implementation of 1 measure from the 3 

practices.

Liquid Manure Requires Implementation of 1 measure from the 5 

practices.

Land Application Requires Implementation of 2 measures from the 

2 practices.

Total 16 of 31

Swine Mitigation Measures

Summary of Swine Mitigation Measures

Area Amended Rule

Feed Requires implementation of 2 measures from the 

3 practices.

Housing Requires implementation of 3 measures from the 

4 practices. 

Liquid Manure Requires implementation of 1 measure from the 4

practice. 

Land Application Requires implementation of 1 measure from the 2 

practices. 

Total 7 of 13
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Layer Mitigation Measure

Summary of Layer Mitigation Measures

Area Amended Rule 

Feed Requires implementation of 1 measure from the 2 

practices.

Housing Requires implementation of 2 measures out of 

the 3 practices. 

Solid Manure/ 

Separated Solids

Requires implementation of 1 measure out of the 

2 practice. 

Liquid Manure Requires implementation of 1 measure from the 4

practices. 

Total 5 of 11

Broiler, Duck or Turkey Mitigation Measures

Summary of Broiler, Duck or Turkey Mitigation Measures

Area Amended Rule 

Feed Requires Implementation of 1 measure out of the 

2 practices.

Housing Requires implementation of 4 measures out of 

the 6 practices. 

Solid 

Manure/Separated 

Solids

Requires Implementation of 1 measure out of the 

2 practices. 

Liquid Manure Requires Implementation of 1 measure out of the 

4 practices. 

Total 7 of 13

VII PUBLIC PARTICIPATION

The Air District conducted two public workshops to collect comments from the 

regulated community and the general public. A first workshop was conducted on 

January 12, 2015. The general public was given an opportunity to comment on 

the rule. As a result to the input and comments provided by the stakeholders 

such as the California Air Resources Board (CARB) and the Environmental 

Protection Agency (U.S. EPA); Cattleman’s Association; Imperial County Farm 

Bureau; and Coalition of Labor, Agriculture, and Business or COLAB; the Air 

District revised Rule 217. Several subsequent meetings were held with different 

stakeholders to gain a better understanding of the operations. In addition, Air 

District held meetings with Federal and State agencies to have input and 

guidance to the Rule amendments and mitigation measures. 

Due to the extensive revisions made to proposed Rule 217, the Air District

conducted a second public workshop on September 24, 2015 to present the 
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revised rule and seek comments from the public and stakeholders. Public 

comments were included in the proposed Rule 217 as appropriate. 

The notices for the workshops were conducted according to policy thus 

advertisements were placed January 7, 2015, September 13, 2015 and 

September 20, 2015 in the Imperial Valley Press announcing the workshops as 

well the Imperial County Air Pollution Control Website.

The proposed Rule 217 and Final Draft Staff Report will be brought before the 

Imperial County Air Pollution Board of Directors on February 9, 2016 for their 

consideration and approval. 

VIII STAFF RECOMMENDATIONS:

APCD ADVISORY BOARD:

The Air Pollution Control Air District Advisory Board met to discuss the revised 

rules on December 2, 2015. The APCD Advisory Board recommended the 

approval of the proposed rule.

STAFF:

The Imperial County Air Pollution Control staff recommends adoption of the

amended Rules 217, 202 and 101 along with the accompanying staff report, 

appendix, and its findings. 

IX DECLARATION OF FINDINGS:

The Imperial County Air Pollution Control District Board hereby finds as follows:

The adoption of the staff report and it’s findings are exempt from the 

requirements of Public Resources Code Section 21000 et seq. under California 

Environmental Quality Act (CEQA) guidelines, in the California Code of 

Regulations Section 15061 (b)(3).

The Air District is a regulatory agency and the public agency with the principle 

responsibility for carrying projects related to Air Pollution and the control thereof.

Clean air is a valuable and essential natural resource.

The staff report and its findings described herein will not significantly affect air 

quality or emissions limitations and therefore is exempt from Health and Safety 

Code (HSC) Section 40728.5, which requires a socioeconomic analysis of the 

proposed action to be performed.
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There has been no evidence presented to suggest that the implementation of the 

staff report and its findings will lead to or result in cumulative adverse impacts.

Health and Safety Code Sections 40701.5 and 40702 provide the authority to the 

Air District to enact this staff report and its findings.

The findings within the staff report are clear and capable of being understood by 

those persons directly affected by it.

The staff report and its findings do not conflict with or contradict any existing 

statute, court decision, or state or federal regulation.

The findings of the staff report are not duplicative of any existing state or federal 

regulation.

The Imperial County has a population of less than 500,000 people.