SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

RULE 4570 (CONFINED ANIMAL FACILITIES)

June 15, 2006 

Prepared by: Lucinda Roth, Air Quality Specialist 

Alvin Valeriano, Senior Air Quality Specialist 

Reviewed by: Maria Stobbe, Planning Manager 

George Heinen, Supervising Air Quality Engineer 

Joven R. Nazareno, Senior Air Quality Engineer 

David Warner, Director of Permit Services 

Sheraz Gill, Senior Air Quality Engineer 

Richard Karrs, Senior Air Quality Engineer 

 Steve Brodie, Air Quality Inspector

 

I. SUMMARY 

A. Reasons for Rule Development and Implementation

In terms of state and federal standards, the California Air Resources Board (ARB) and 

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

Air Basin (SJVAB) as a non-attainment area for ozone. The District is classified as a 

serious non-attainment area for the federal 8-hour ozone National Ambient Air Quality 

Standards (NAAQS). It is anticipated that attainment of the eight-hour standard will 

require the control measures cited in the one-hour Extreme Ozone Attainment Plan 

(Ozone Plan), which include control measure 4570 (Confined Animal Facilities). Since 

Proposed Rule 4570 is a control measure in the District’s Ozone Plan, it is subject to 

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

requirements. Additionally, anti-backsliding provisions commit the District to develop all 

control measures listed in the Ozone Plan (Federal Register Volumes 69 and 70). 

These requirements are summarized in Table 1. 

Final Staff Report with Appendices 

For Proposed Rule 4570
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Table 1 

Anti-backsliding and Ozone Plan Commitments 

Subject Reference Requirement 

Antibacksliding 69 Federal Register 

23955 

Districts shall develop all control measures 

listed in the one-hour Ozone Plan until the 

District is designated as attainment for the 8-

hr NAAQS.

BACM Federal Register 

8/18/94 

Provisions in attainment plans should include 

the application of best available control 

measures (BACM) to existing major stationary 

sources. 

BARCT 

CH&SC 40919(a)(3) 

Ozone Plan 

 Ozone attainment plans should provide for 

best available retrofit technology (BARCT) for 

existing permitted sources. 

 BARCT is specifically required for "large" 

Confined Animal Facilities (CAF). 

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

Feasible 

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

RACT CAA 182(b)(2) and 

182(f) 

Ozone attainment plans shall assure that 

reasonable available control technology 

(RACT) for volatile organic compounds (VOC) 

is in use at sources and on source categories 

at or above the RACT threshold. 

RACT 

Threshold 

70 Federal Register 

30592-30596 

The applicable RACT threshold for control 

measures shall be the threshold in effect on 

June 15, 2004. The Districts threshold on 

June 15, 2004 was 10 tons per year (tpy) for 

VOC. Therefore, 10 tpy is the RACT 

threshold for Proposed Rule 4570. 

Reductions Ozone Plan 

The rule shall reduce VOC emissions by at 

least 25% from the baseline by 2010. Twentyfive percent of the baseline used for the 

Ozone Plan (63.1 tpd) is 15.8 tpd. 

Timeline CAA Section 

172(c)(1) 

Ozone attainment plans shall implement 

control measures as expeditiously as 

practicable, and provide for attainment. 
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Proposed Rule 4570 is also intended to fulfill the following CH&SC requirements 

created by the passage of California’s Senate Bill 700 (SB 700): 

Table 2 

SB700/California Health and Safety Code Requirements

Subject CH&SC Sections SB700 / CH&SC Requirements 

Large Confined Animal 

Facility Definition (large 

CAF) 

40724.6(a) 

The District shall use the "large CAF" definition 

developed by the California Air Resources Board 

(ARB). 

Deadline 40724.6(b) 

By July 1, 2006 the District shall adopt, implement, and 

submit for inclusion in the state implementation plan a 

rule requiring owners of "large" CAF to obtain a permit. 

Degree of Mitigation 

Required 40724.6(d)(1)(B) Best Available Retrofit Control Technology (BARCT) is the degree of mitigation required of large CAF. 

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

within one year of the permit issuance date. 

Permit Requirements to 

be Included in the Rule 40724.6(d) 

1. The permit shall include an emission mitigation plan 

that demonstrates use of BARCT, 

(Rule 4570 Section 5.0) 

2. The District shall provide for a 30-day public noticing 

and commenting period for proposed permits, 

(Rule 4570 Section 6.1.6) 

3. The District shall review and update permits at least 

once every three (3) years, (Rule 4570 Section 6.2) 

4. The District shall act on completed permit 

applications within six (6) months of receipt, 

(Rule 4570 Section 6.3) 

5. The permit shall include sufficient information to 

prepare an emission inventory of all regulated air 

pollutants emitted from the facility, and 

(Rule 4570 Sections 6.0 and 7.0) 

6. The owner/operators of large CAF shall submit a 

permit application within six (6) months of Rule 4570 

adoption. (Rule 4570 Section 8.1) 

Impact Assessment 40724.6(d) 

Prior to adopting a rule, the District shall analyze the 

following: 

1. Category, number, and size of facilities affected, 

(Section II of the Staff Report) 

2. Nature, quantity, and significance of emissions in 

adversely affecting public health, the environment, 

and attainment of air quality standards, 

 (Section IB and Section II of the Staff Report) 

3. Emission reduction potential, (Appendix B) 

4. Costs, (Appendix C and D) 

5. Impact on employment and the economy, 

(Appendix D) 

6. Alternative controls, and (Section III of the Staff 

Report) 

7. Technical and Practical Feasibility. 

 (Section III of the Staff Report) 
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B. Scope of Proposed Rule 4570 

Rule 4570 is properly limited to VOC regulation. Proposed Rule 4570 was developed 

pursuant to California Health and Safety Code (CH&SC) 40724.6, which applies only to 

the regulation of ozone and ozone precursors. This is confirmed by CH&SC 

40724.6(d)(1)(B), which requires, amongst other things, the implementation of 

reasonably available control technology (RACT) in "moderate" and "serious" 

nonattainment areas, and best available retrofit control technology (BARCT) in "severe" 

and "extreme" nonattainment areas. "Severe" and "extreme", as used in these sections 

of the CH&SC, are legal terms that pertain only to ozone attainment status. Please see 

CH&SC 40724.6(d)(1)(B) for additional information. Due to the fact that the 

aforementioned sections only apply to ozone and ozone precursors, controlling 

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

permitted. 

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

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

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

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

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

Proposed Rule 4570 must regulate ammonia because CH&SC 40724(a) requires 

BARCT controls for particulate matter (PM) precursors, and ammonia is a precursor for 

both PM10 and PM2.5. The District disagrees with this comment for several reasons. 

First, as discussed above, Rule 4570 is being adopted pursuant to CH&SC 40724.6, 

which authorizes the regulation of ozone, not particulate matter. The District complied 

with CH&SC 40724(a) when it adopted its Rule 4550 (Conservation Management 

Practices) in May and August 2004. To the extent that the commenters believe that 

ammonia should have been regulated under that rule, their comments are misplaced in 

this rule development process, as this is a separate district rulemaking activity. 

However, in an effort to respond to these comments, the District offers the following: 
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Ammonia was not targeted by Rule 4550 because, based on the District's PM-10 Plan; 

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

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

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

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

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

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

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

to regulate PM precursors "in a manner commensurate to other source categories." 

Since current District rules do not require any other source category to control 

ammonia, this rule cannot do so for confined animal facilities. In addition, the District 

did not regulate PM2.5 in Rule 4550 because CH&SC 40724(a) applies only to the 

regulation of PM in federal nonattainment areas designated as nonattainment for PM2.5 

as of January 1, 2004. The San Joaquin Valley was not designated as nonattainment 

for PM2.5 until April 5, 2005, well after the January 2004 applicability date. Thus, 

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

Valley. 

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

CH&SC 40724.6 applied to all "air contaminants" as commenters suggest, CH&SC 

40724.6(b) requires that emissions from a facility be reduced "to the extent feasible." In 

order to be "feasible" emission reductions must have some relationship to the pollution 

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

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

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

regulation would not survive the required socioeconomic analysis because the money 

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

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

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

would duplicate controls required for particulate matter in Rule 4550. CH&SC 

40724.6(h) states that "nothing in this section authorizes a district to adopt a rule or 

regulation that is duplicative of a rule or regulation adopted pursuant to CH&SC 40724 

and 40724.5." As discussed above, Rule 4550 (Conservation Management Practices) 

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

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

ozone rule, Proposed Rule 4570, could not similarly regulate particulate matter pollution 

as that would be "duplicative" and thus in violation of CH&SC 40724.6(h). 
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Finally, CH&SC 40724.6(d)(4)(d) states that the District must consider the impacts of a 

rule adopted under the aforementioned section and assess, amongst other things, "the 

nature and quantity of emissions from the category and the significance of those 

emissions in ... causing or contributing to the violation of a state or federal ambient air 

quality standard." As discussed above, the District performed this analysis for ammonia 

when it adopted it PM10 Plan in 2003 and again when it adopted an update to that Plan 

in 2006. This analysis determined that controlling ammonia is not an effective strategy 

for reducing particulate matter in the Valley. This analysis was affirmed by the Ninth 

Circuit in Association of Irritated Residents vs. U.S. Environmental Protection Agency. 

However, even though the District is not required to regulate ammonia with this rule, it is 

important to note that many of the mitigation measures required by the rule to reduce 

VOCs also reduce ammonia. As a result, this rule is expected to reduce ammonia from 

large CAFs by over 30%, as demonstrated in Appendix F. 

The District also analyzed NOx pursuant to CH&SC 40724.6(d)(4)(d). Although NOx is 

an ozone and particulate matter precursor, Rule 4570 does not require NOx controls at 

CAFs. This is because animals and manure emit minimal quantities of NOx. 

Furthermore, the scope of this rule is limited to animal husbandry including manure 

disposal, not engines on these facilities. However, the District implemented BARCT for 

NOx emissions on CAFs from engines, boilers, and other sources in other District Rules 

including, but not limited to, District Rules 4301, 4304 through 4308, and 4701 through 

4703. 

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

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

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

pollutants that contribute to the District’s non-attainment status for ozone. 

C. Large CAF Definition

A CAF is defined in CH&SC 39011.5(a) and 39011.5(a)(1). Based on these sections of 

the CH&SC, a CAF is "a source of air pollution or a group of sources used in 

the...raising of fowl or animals located on contiguous property under common ownership 

or control...including, but not limited to, any structure, building, installation, barn, corral, 

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

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

penned, or otherwise caused to remain in restricted areas for commercial purposes and 

feeding is by means other than grazing." 

The California Air Resources Board (ARB) was required by CH&SC 40724.6 to "review 

all available scientific information, including, but not limited to, emission factors for 

confined animal facilities; the effect of those facilities on air quality in the basin; and 

other relevant scientific information and to develop a definition for a "large" confined 

animal facility. ARB's board adopted the following thresholds for a large CAF, based on 

air emissions from CAFs: 
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Table 3: ARB Large CAF Thresholds 

Livestock Category Number of Animals 

Dairy 1,000 lactating cows 

Beef Feedlots 3,500 beef cattle 

Other Cattle Operations 7,500 calves, heifers, and other cattle 

Chickens-Broilers & Egg Layers 650,000 head 

Turkeys 100,000 head 

Swine 3,000 head 

Sheep and Goats 15,000 head 

Horses 2,500 head 

Ducks 650,000 head 

Other Livestock Not Previously Mentioned 30,000 head 

Source: http://www.arb.ca.gov/regact/lcaf05/lcaf05.htm accessed 2/24/06 

D. Permits Requirements 

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

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

findings, as quoted below: 

"A district may require a permit for a large confined animal facility with actual 

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

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

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

that requirement, the district makes both of the following determinations in a public 

hearing: 

(1) A permit is necessary to impose or enforce reductions in emissions of air 

pollutants that the district show cause or contribute to a violation of a state or 

federal ambient air quality standard and 

(2) The requirement for a source or category of sources to obtain a permit would not 

impose a burden on those sources that is significantly more burdensome than 

permits required for other similar sources of air pollution." (CH&SC 40724.6) 

Staff believes that without a permit, determining compliance with Proposed Rule 4570 

and ensuring compliance would not be feasible. A permit is the legal document through 

which we enforce the rule for permitted sources. Furthermore, since many of the 

affected sources already have permits and this rule would only require a modification to 

their existing permits, staff does not believe the permit requirement in Proposed Rule 

4570 would impose a burden. The District will make these findings at a public hearing 

on June 15, 2006. 
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E. RACT Requirements 

Reasonably Available Control Technology (RACT) is required by CAA 182(b)(2) and 

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

emissions factors for confined animal facilities are being revised; therefore, it is not 

possible to conclusively identify the number of animals of any species that would trigger 

RACT requirements. The development of this rule cannot be postponed until 

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

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

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

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

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

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

to address CAFs below the large CAF definition, but at or above the ten (10) tpy 

emission threshold for RACT, if it is determined that such sources exist. 

F. Scientific Background Review/Revision 

Due to the relatively new status of CAFs as a regulated stationary source, the body of 

scientific knowledge that is useful in understanding its impact on air pollution is not as 

well established compared to other traditional stationary sources under the jurisdiction 

of the District. New scientific findings characterizing and quantifying dairy, poultry, and 

other animal emissions and possible control measures are being developed and 

completed. The District developed Proposed Rule 4570 using relevant findings from 

previous research efforts as they were finalized, published, and peer-reviewed. These 

include, but are not limited to: 

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

from cows housed in environmental chambers to evaluate the emissions 

produced directly from cows and their fresh manure. 

• A study at two operating dairies in the San Joaquin Valley, led by Dr. Chuck 

Schmidt, in which measurements were made at various locations at the dairies, 

including the corrals and turnouts, bedding areas, lagoons, feed storage areas, 

flush lanes, and bunker feed. 

• A study by Dr. Schmidt to validate the effectiveness and capture efficiency of 

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

These studies have provided significant findings that provide an understanding of the 

emissions at CAFs. Due to the rule adoption date mandated by CH&SC 40724.6 and 

the presence of peer-reviewed and preliminary research data, staff will propose rule 

adoption no later than July 1, 2006. 

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

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

requirements utilizing management practices and machinery that owners/operators 
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already have access to onsite. This is intended to implement BARCT, while preventing 

owners/operators from being required to invest significant capital in a technology that is 

later found to control only a small portion of the emissions. Staff may amend this rule 

after July 1, 2006 when additional research is completed, which may require 

owners/operators to make capital investment beyond the mitigation measures currently 

being proposed in Rule 4570. At that time, the emissions from each area would be 

better quantified, and staff would be able to determine which VOC emission mitigation 

measures have the highest cost effectiveness values. 

Since testing methods are being developed, staff left the testing requirements flexible to 

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

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

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

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

continues, new, more effective, and less expensive test methods may be developed 

and, if so, owner/operators should be allowed to use such methods. 

While the studies by Dr. Schmidt and Dr. Mitloehner have provided valuable new 

information, they do not fully address air emissions from CAF. Additional work is 

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

for CAF. As additional research, such as that being undertaken by the California Air 

Resources Board, becomes finalized, this rule may be adjusted to incorporate that new 

information. Please see Appendix H for additional information on ongoing studies. 

II. BACKGROUND 

CAF are used for the raising of animals including, but not limited to, cattle, calves, 

chickens, ducks, goats, horses, sheep, swine, rabbits, and turkeys, which are corralled, 

penned, or otherwise caused to remain in restricted areas for commercial agricultural 

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

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

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

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

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

owners/operators. This acknowledges that not all facilities can implement the same 

options due to infrastructure, conditional use permits, water board permits, soil types, 

production contracts, and other limitations. It also enables the people that understand 

the particular operation best, the owners/operators, to choose the mitigation measures 

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

A. General Description of Poultry Operations 

Poultry facilities operate either as layer ranches for egg production or as broiler ranches 

where birds are grown for the fresh meat market. Poultry facilities, called ranches in 
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reference to their specialized operation, may consist of one or more farms on properties 

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

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

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

approximately 10,000 birds at any one time. 

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

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

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

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

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

single agricultural source in CH&SC Sections 39011.5(a) and 39011.5(a)(1). Therefore, 

the majority of the existing poultry operations are expected to be below the thresholds 

established for control requirements. 

In the United States, approximately 61% of the chicken layer houses and a majority of 

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

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

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

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

for ventilation, particularly during colder weather. 

Studies indicate that most chicken layer houses produce approximately two cubic yards 

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

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

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

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

positioned above the ground. On average, every seven (7) to nine (9) days workers 

remove waste from under the layer boxes, and every fourteen (14) to eighteen (18) 

weeks workers remove waste from the floor of the layer houses. However, many 

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

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

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

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

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

4570. 

In broiler facilities, complete litter removal from the house occurs one (1) to four (4) 

times per year. Litter removal frequencies vary from every two (2) to seven (7) flocks 

(approximately 90-315 days); more commonly, it is removed every third flock. Before 

introducing a new flock, the house is left empty, typically for five (5) days. During this 

interlude, the operator adjusts the temperature and other ambient conditions in the 

house. In the broiler industry, the new flocks of birds are brought into the houses as 

chicks and are raised for approximately 45 days, until they reach the desired weight. 

Shortly thereafter, the grown birds are removed and the house is again left empty for 
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approximately five (5) days to sanitize. This approximately 55-day cycle is the 

production period for one flock. Depending on management practices, litter production 

ranges from 0.5 to 0.7 pounds per pound of live bird weight. On average, for each 

pound of live weight gained, meat birds produced 0.52 pounds of litter during the 

production period. 

 

Poultry excretions and bedding materials, such as rice hulls, are removed either by 

scraping or by flushing. In a scrape system, the litter is either swept or scraped from the 

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

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

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

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

Valley use liquid manure handling systems. 

Based on current preliminary research data, litter and feed are the major sources of 

VOC emissions. These emission points are also sources of ammonia emissions. Since 

ammonia forms a significant health risk to the animals and decreases productivity, many 

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

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

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

facilities in the SJVAB already implement BARCT for VOC emissions. Furthermore, the 

studies conducted to determine emissions factors for poultry were on poultry houses 

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

 

B. Dairy Operations 

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

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

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

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

typically peaks shortly after calving and then declines. Commonly a cow will produce 

milk for ten (10) to twelve (12) months and then be dry approximately two (2) months. 

Thus, a dairy operation may have several types of animal groups present including 

heifers, lactating cows, dry cows, calves, and bulls (for breeding purposes). 

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

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

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

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

aforementioned. The freestall barn is the predominate type of housing system used on 

dairy farms for lactating cows. In a freestall barn, cows are housed in large pens with 

free access to feed bunks, waterers, and stalls for resting. Standard freestall barns 

have a feed alley in the center of the barn separating two feed bunks on each side. 

Animals stand on the corral side of the feed lane to eat; this is where the majority of the 

animal excretion occurs. In some cases, cows may be confined in or have access to 
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drylots. Drylots are typically fenced in areas that may have shade. Drylot confinements 

are similar to beef feedlots described later in this report. Tie stalls/stanchions are not 

uncommon on smaller dairy farms and older facilities. In this type of housing system, 

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

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

stalls for manure collection and removal. 

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

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

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

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

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

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

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

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

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

manure tends to be generated in a semi-solid state. 

Manure with a total solid content of 10% or less can be handled as a liquid. In slurry or 

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

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

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

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

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

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

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

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

and dried for disposal through land application. 

C. General Description for Beef Cattle Feeding Operations 

This animal sector includes adult beef cattle (heifers and steers). Beef may spend all, 

part, or none of their lives on a CAF. There are three types of operations in the beef 

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

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

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

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

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

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

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

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

bone mass at a low cost. The duration of the backgrounding process may be from thirty 
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Final Staff Report with Appendices 

For Proposed Rule 4570 13

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

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

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

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

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

typically have between 1.5 to 3.5 cattle turnovers per year. 

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

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

bunks located along feed alleys that separate the individual pens. 

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

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

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

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

associated with entering areas where beef cattle are housed. 

D. General Description for Swine Operations 

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

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

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

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

approximately ten (10) to fifteen (15) pounds. Typically, there are from nine (9) to 

eleven (11) pigs per litter. Sows can be bred again within a week after a litter is 

weaned. Sows normally produce five (5) to six (6) litters before they are sold for 

slaughter at a weight of 400 to 460 pounds. 

Weaned pigs are fed a starter ration until they reach a weight of approximately fifty (50) 

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

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

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

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

as wheat and barley, corn and soybean meal. 

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

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

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

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

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

through slats in the floor to a pit underneath the floor. Manure in the pit may be flushed 

or scraped. 
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For Proposed Rule 4570 14

E. Land Application of Animal Waste

Liquid manure from flush systems stored in lagoons or solid manure scraped from 

facilities eventually may be land applied with or without prior treatment such as 

composting or anaerobic digestion. Typically, animal waste is applied to cropland at 

rates adequate to supply crop nutrient needs. Historically the determination of 

application rates has been based on crop nitrogen requirements due to concern about 

the impact of excess nitrogen on surface and ground water. In cases where treatment 

methods, such as aerobic digestion, increase the nitrogen content in the waste stream, 

the waste may need to be applied over a greater number of acres in order to comply 

with the Regional Water Quality Board’s regulations. 

Surface application of manure waste may be done with a spreading device known as a 

box manure spreader. This is simply a rectangular box that is either tractor drawn or 

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

moves to the rear of the box by either a belt or chain-and flight conveyor. Box type 

spreaders are typically loaded with tractor mounted front-end loaders. Manure handled 

as slurry or liquid may be spread with a tractor drawn or truck mounted tank known as a 

liquid manure spreader. The manure may be forced out of the tank under pressure 

against a distribution plate to create a spray pattern. Another option is to force the 

manure from the tank under pressure through a manifold with a series of hanging or 

trailing pipes to create parallel strips of manure on the soil surface. A second type of 

spreader for manure slurries is a flail spreader. This is a partially open tank with chains 

attached to a rotating shaft positioned parallel to the direction of travel. Manure is 

discharged perpendicular to the direction of travel by the momentum transferred from 

rotating chains. 

Manure may be land applied and land incorporated through the use of a manure 

injection device, typically attached to a tractor; tilling surface applied manure under the 

soil; applying liquid manure at such a rate that is rapidly absorbed into the soil; or 

another method in which the manure is covered with soil. 

Facilities choosing to use conservation tillage options will likely apply any liquid manure 

at a rate such that it is rapidly absorbed into the soil and apply any solid manure only 

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

digestion process, or dried to a moisture content of less than 50%. In any of these 

cases the animal waste land applied would not need to be tilled under the soil in order 

to comply with rule requirements. Similarly, such methods may be used when crop 

height prevents the owner/operator from tilling the land-applied waste. 

F. Emission Characterization 

Current research suggests that general sources of VOC on CAF may include: enteric 

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

excreta, the majority of the non-methane volatile organic compounds (NMVOC) 
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Final Staff Report: Rule 4570 (Confined Animal Facilities) June 15, 2006 

Final Staff Report with Appendices 

For Proposed Rule 4570 15

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

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

solid separator piles, and lagoons. 

The District extensively reviewed current research in the APCO reports available at: 

http://www.valleyair.org/busind/pto/dpag/dpag_idx.htm 

 The District identified the following emission categories: 

• Category 1- Feed and Enteric from an Environmental Chamber: Several VOC 

including aromatics and ethanol were not measured. Ethanol was the main VOC 

found in feed in Dr. Chuck Schmidt's study; 

• Category 2- Ethylamines from Specific Dairy Processes: Does not include 

emissions from several processes, including feed storage, land application, and 

composting; 

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

methanol were not measured and several important processes including feed 

storage, land application, and composting were not included; 

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

aromatics and ethanol were not measured; 

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

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

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

regarding the relationship between phenol formation and diet and process 

conditions was provided to the APCO; and 

• Category 7- Land Application, Feed Storage, Settling Basins, Composting, and 

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

these sources.

The emission categories listed above contribute to emissions in the following emission 

sources (locations) on a CAF are: 

• Feed, 

• Housing,

• Land Application (if applicable),

• Milking Center (if applicable),

• Liquid Waste Handling Systems (if applicable), and

• Solid Waste Handling Systems (if applicable).
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Final Staff Report with Appendices 

For Proposed Rule 4570 16

Not every facility has all of the above emission sources due to differences in operating 

and farming practices. 

G. Emission Factors 

To calculate source emissions, reductions, and cost effectiveness of control measures, 

staff required emission factors. The emission reduction calculations are performed 

using the most recent emission factors accepted by the District at the time of the 

calculation. 

Emission factors come from a variety of sources: 

• The emission factor for swine, rabbits, horses, sheep, and goats are based on a 

metabolism study conducted in 1938 by Benedict and Ritzman. This study 

measured methane in animals including an elephant, a horse, seven (7) 

Holsteins, four (4) Jerseys, and a Hereford cow. This study and the subsequent 

research papers based on it remain the most currently published and reviewed 

source of emission factors for several species. Several most recent articles have 

reported different emissions from these operations and emission sources. 

However, those emission factors tend to be inconsistent, possibly due to 

variation between facilities, and are not complete. Staff was unable to locate 

comparable emission factor data that addressed all emission sources on these 

facilities. Therefore, the Ritzman study and Ritzman-based studies are currently 

considered the most complete, published, and peer reviewed source of emission 

factors for these facilities. Additionally they are the factors listed in the ARB 

October 2003 interim proposed report on emission factors. 

• The remaining emission factors are those currently used by the District's Permit 

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

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

chicken broiler facility; information from the Dairy Permitting Advisory Group 

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

ASAE manure production equivalents. 

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

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

permitting process to reflect the latest approved research information. 
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For Proposed Rule 4570 17

Table 4: Emission Factors (as of 4-26-06) 

Animal Type VOC Emission Factor 

(lb/hd-yr)

Milking Cow 19.3 to 21.7* 

Dry Cow 11.9 

Heifer (15-24 months) 8.3 

Heifer (7-14 months) 7.2 

Heifer (4-6 months) 6.6 

Calf (under 4 months) 6.2 

Feedlot Cattle 11.1 

Laying Hens and Associated 

Birds 0.05 

Broiler Chickens and 

Associated Birds 0.025 

Turkeys and Associated Birds 0.10 

Swine 4.6 

Rabbits 0.19 

Horses 6.7 

Goats and Sheep 0.96 

* The emission factor for lactating cows varies based on the 

type of housing. Cows in a complete flush dairy with no 

freestalls have an emission factor of 19.3 lb/hd-yr and cows in 

a complete flush dairy with freestalls have an emission factor 

of 21.7 lb/hd-yr. On the website the 21.0 lb/hd-yr value is 

listed because it is the weighted average of the number of 

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

animals in facilities without freestalls (29%). Specifically, the 

calculation is: 21.7 x 71% + 19.3 x 29% = weighted emission 

factor = 21.0 lb/hd-yr. 

H. Animal Inventory and Emissions 

Staff utilized the 2002 USDA census, industry data, and California Air Resources Board 

documents to estimate the VOC's emitted by CAFs in the SJVAB. The methodology is 

further explained below; Table 5 summarizes the results. 
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Final Staff Report: Rule 4570 (Confined Animal Facilities) June 15, 2006 

Final Staff Report with Appendices 

For Proposed Rule 4570 18

Total VOC Emitted 

by CAFs (lb/yr)

Total VOC Emitted by

CAFs (tons/day)

Total VOC Emitted 

by Large CAFs (lb/yr)

Total VOC Emitted by 

Large CAFs (tons/day)

Milk Cows 37,432,525 51.28 26,951,418 36.92

Beef Cattle 2,042,955 2.80 1,940,807 2.66

Other Cattle 11,355,375 15.56 10,795,230 14.79

Poultry 2,583,221 3.54 1,574,625 2.16

Swine 729,266 1.00 414,000 0.57

Other Animals 296,383 0.00 0.00 0.00

Total Animals 54,439,725 74.57 41,676,080 57.09

 Table 5: Total 2005 VOC Emissions from CAFs in the SJVAB

Dairy

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

“California Agricultural Statistics 2004." The numbers are shown in Table 6. These 

numbers only include milking and dry cows, not heifers that have not calved or calves. 

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

County 2002 2003 2004 Projected 

2005* 

Fresno 86,115 90,345 95,577 99,878 

Kern 85,830 98,478 121,147 126,599 

Kings 146,545 153,475 162,656 169,976 

Madera 49,899 57,099 63,934 66,811 

Merced 224,895 224,734 237,854 248,557 

San Joaquin 99,828 106,162 103,619 108,282 

Stanislaus 164,558 177,432 178,420 186,449 

Tulare 424,643 437,476 442,853 462,781 

Total 1,282,313 1,345,201 1,406,060 1,469,333 

*The growth from 2002 to 2003 was approximately 4.9% and the growth from 

2003 to 2004 was 4.5%. In order to be conservative, staff assumed a growth of 

4.5% for 2004 to 2005. 

In order to estimate the number of support stock at a dairy, ratios were developed using 

216 dairy applications submitted to the District. Based on those applications the 

following ratios, listed in Table 7, were developed. These ratios represent the number 

of each type of animal. 
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For Proposed Rule 4570 19

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

Support 

Animals to 

Milkers 

Dry 

Cows 

to 

Milkers 

Heifers (15-

24 mo) to 

Milkers 

Heifers (7-14 

mo) to 

Milkers 

Heifers (4-6 

mo) to 

Milkers 

Calf 

(<4 mo) to 

Milkers 

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

Before the above ratios can be applied to the CDFA milk and dry cow numbers to 

estimate a total number of head, the number of dry cows needs to be subtracted from 

the milk and dry cow numbers. Based on the ratios above, 16% of cows are dry cows 

when compared to milk cows, therefore the calculations would be as shown in the 

example below: 

1,469,333/1.16 = 1,266,666 milk cows 

1,266,666 x 0.16= 202,667 dry cows 

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

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

Staff assumed, based on the ARB's June 23, 2005 Staff Report for Confined Animal 

Facilities page iii, that 72% of the dairy cows would be included in this regulation. 

Furthermore, since the APCO Report noted that the 19.3 lb/hd-yr factor did not consider 

all emission sources and that the majority of facilities have freestalls, in order to be 

conservative, Staff utilized the weighted emission factor of 21.0 lb/hd-yr listed on the 

District's web page for dairies. 

Total 

Animals

VOC Factor 

(lb/hd/yr) 

from Table 4

Total VOC 

Emissions 

(lb/yr)

Animal 

Included In 

Rule

VOC Factor 

(lb/hd/yr) 

Total VOC 

from Animals 

Included in 

Rule (lb/yr)

Milk Cows 1,266,666 21.00 26,599,994 912,000 21.00 19,151,996 

Dry Cows 202,667 11.90 2,411,733 145,920 11.90 1,736,448 

Heifers (15-24) 430,667 8.30 3,574,533 310,080 8.30 2,573,663 

Heifers (7-14) 367,333 7.20 2,644,799 264,480 7.20 1,904,256 

Heifers (3-6) 202,667 6.60 1,337,600 145,920 6.60 963,072 

Calves 139,333 6.20 863,866 100,320 6.20 621,984 

Total Cows 2,609,333 37,432,525 1,878,720 26,951,418 

 Table 8: Total 2005 Dairy Animals in SJVAB

Beef and Other Cattle

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

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

California Farm Bureau Federation. Staff assumed, based on the ARB's June 23, 2005 
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Final Staff Report with Appendices 

For Proposed Rule 4570 20

Total 

Animals

VOC Factor 

(lb/hd/yr) 

from Table 4

Total VOC 

Emissions 

(lb/yr)

Animal 

Included In 

Rule

VOC Factor 

(lb/hd/yr) 

Total VOC 

from Animals 

Included in 

Rule 

Staff Report for Confined Animal Facilities page 8, that 95% of the beef cattle and other 

cattle would be included in this regulation. This is based on the assumption that a 

similar number of beef and other cattle would be included in this rule as feedlot cattle 

listed in the ARB Staff Report. 

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

calves at the other cattle facilities therefore, averaged the emission factors for heifers 

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

develop Table 9. 

 

(lb/yr)

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

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

Total 1,789,050 13,398,330 1,699,598 12,736,037 

 Table 9: Total 2005 Beef and Other Cattle

Poultry and Other Animals

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

data. Since the ARB Proposed Emission Methodology assumed no significant growth 

for layers, staff assumed that the layer population has been relatively constant since 

2002. Based on ARB June 23, 2005 Public Hearing to Consider the Adoption of a 

Regulation Establishing a Definition of BACT, staff assumed that 62% of the layers are 

housed in large CAFs. 

Staff obtained estimates of the number of broilers and turkeys in the SJVAB from the 

California Poultry Federation. Based on this information, staff determined the number of 

turkeys and broilers housed in large CAFs. 

Total 

Animals

VOC Factor 

(lb/hd/yr) 

from Table 4

Total VOC 

Emissions 

(lb/yr)

Animal 

Included In 

Rule

VOC Factor 

(lb/hd/yr) 

Total VOC 

from Animals 

Included in 

Rule (lb/yr)

Layers 11,717,799 0.050 585,890 7,265,035 0.050 363,252 

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

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

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

 Table 10: Total 2005 Poultry Animals

Staff obtained an estimate of the number of rabbits, goats, sheet, and swine in the 

SJVAB from the USDA census data. Since ARB Proposed Emission Methodology 

assumed no significant growth for non-cattle, staff assumed that the non-cattle 
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Final Staff Report: Rule 4570 (Confined Animal Facilities) June 15, 2006 

Final Staff Report with Appendices 

For Proposed Rule 4570 21

Total 

Animals

VOC Factor 

(lb/hd/yr) 

from Table 4

Total VOC 

Emissions 

(lb/yr)

Animal 

Included In 

Rule

VOC Factor 

(lb/hd/yr) 

Total VOC 

from Animals 

Included in 

Rule (lb/yr)

Rabbits 3,903 0.190 742 0.190 - -

Goats 34,160 0.960 32,794 0.960 - -

Sheep 273,800 0.960 262,848 0.960 - -

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

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

 Table 11: Total 2005 Other Animal

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

database, staff found that approximately 90,000 swine are housed in large CAFs 

and no rabbits, goats, or sheep in the SJVAB are housed in large CAFs. This is 

illustrated in Table 11.

s

I. Industry Description 

The SCAQMD's dairy rule includes all facilities with 50 cows of any type, but the 

average dairy in SJVAB is over twice the size of dairies in the SCAQMD. Furthermore, 

the majority of the dairies in the SCAQMD are scrape dairies, many of which transport 

their manure off the dairy and into the SJVAB. In 2003, according to the Santa Anna 

Regional Water Quality Board, over 157,400 tons of manure was shipped from the 

Chino Basin to the SJVAB. Many of the SJVAB dairies use a flush waste control 

system instead of scrape waste removal system. Furthermore, dairies in the SJVAB do 

not typically ship manure out of the Valley but efficiently reuse their manure and flush 

water on adjacent or nearby crops. Therefore, staff does not believe the SCAQMD 

dairy operations are comparable to the SJVAB dairy operations. 

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

Rule 4570 applicability thresholds. Information from the California Poultry Federation, 

District's permit database, and CDFA estimates and surveys was used to identify all 

other facilities that would likely be required to implement practices that they do not 

already utilize. Please note that a significant number of CAF already utilize enough 

mitigation options listed in the rule to comply with the rule requirements. Staff estimated 

the number of swine facilities affected by using 2002 USDA census data. By 

subtracting the maximum and minimum number of swine in facilities with fewer than 

1,000 head from the total number of swine in each county, staff estimated the number of 

swine facilities that would be affected. This is summarized in Table 12. 
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For Proposed Rule 4570 22

Table 12 

Estimated Number of Facilities Affected by the Rule 

Animal Type Number of Large 

CAFs 

Number of Facilities 

That Will Likely Be 

Implementing New 

Practices 

Dairy 430 233 

Beef Feedlots <16 6 

Other Cattle 

Operations <16 5 

Swine 1 to 3 1 to 3 

Poultry <61 0 

J. Source Growth

Overall, the livestock inventory in the SJVAB increased between 2 and 6% per year 

over the last 12 years. A significant portion of this growth is due to increases in the 

number of milk cattle. According to the USDA 2002 Census data and California 

Department of Food and Agriculture (CDFA) Statistics Annual from 1998 and 2002, the 

inventory of milk cattle in the SJVAB increased over 30% from 1997 to 2002. Local 

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

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

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

geese from 1997 to 2002. Based on CEQA projects submitted to the District, the 

inventory of dairy cattle in the SJVAB would increase over 25% in the next three years, 

if all the proposed projects were completed. Although it should be noted that some of 

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

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

III. EMISSION CONTROL TECHNOLOGY 

This section summarizes the requirements for control and the possible control 

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

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

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

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

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

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

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

measures. 
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For Proposed Rule 4570 23

A. Technology Requirements 

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

With the changes to the CH&SC and the resulting loss of exemption from permitting of 

agricultural sources of air pollution (CH&SC 39011.5 (b)), new or expanded CAFs may 

now be required to undergo the BACT process as a requirement under New Source 

Review (NSR). District Rule 2201 (New and Modified Stationary Source Review Rule) 

implements state and federal requirements under Title I, Part D and requires BACT for 

new sources or sources undergoing modification with emission increases that are above 

the de minimis value (two (2) pounds per day of VOC). BACT provisions would apply to 

sources which are subject to District permitting requirements and that emit or may emit 

one or more affected pollutant, either as a “major” source subject to Title V permitting or 

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

thresholds. 

Beginning July 1, 2004, large CAFs, as defined by the ARB, and CAFs with emissions 

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

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

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

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

prohibitory rules, which are local rules other than permitting rules. 

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

As mentioned previously, CAFs defined as “large” by the ARB will be required by 

Proposed Rule 4570 to submit emission mitigation plans. The level of mitigation 

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

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

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

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

are more options available at a more reasonable cost when a source is being designed, 

than there are after it is built, especially if it was built a long time ago. California law 

established an intermediate level of control that is the “best available” for “retrofit” to 

existing sources, recognizing that the state’s air pollution problems may demand more 

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

air districts have adopted many rules to implement BARCT, including particulate control 

efficiency standards and limitations on exhaust pollutants and technology-based 

requirements that dictate the use of a particular control device or something that is 

equally effective. 

BACT vs. BARCT

As discussed above, the purposes of BACT and BARCT are different. BACT is 

designed to minimize the growth in future stationary source emissions; BARCT is 
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For Proposed Rule 4570 24

designed to reduce current stationary source emissions. BACT is utilized in the 

permitting process on a case-by-case basis. BARCT is considered for application on an 

industry-wide basis in the rule development process.

B. Feed and Silage Mitigation Measures 

Feed According to National Research Council Guidelines

Dietary manipulation of feed formulations, a practice commonly used to improve animal 

health and productivity, has been shown to reduce VOC emissions from cow flatulence 

(enteric) and manure. Emission reductions of at least 10% for ammonia, hydrogen 

sulfide, and VOC were found (Klaunser, 1998 J Prod Agric). However, studies 

regarding efficiency of dietary manipulation to reduce VOC conflict. This may be due to 

variations in feed formulations. Staff is considering the National Research Council's 

(NRC) recommendations regarding the nutrient requirement for different animals as an 

appropriate feed formulation to minimize VOC emissions from cow flatulence (enteric) 

and manure, while ensuring that animal health is not jeopardized. The National 

Research Council considered environmental, animal productivity, animal health, and 

energy concerns in developing their guidance for nutrient requirements for animals. 

The guidance is located in the following publications: 

• Nutrient Requirements of Beef Cattle, 2000;

• Nutrient Requirements of Dairy Cattle, 2001;

• Nutrient Requirements of Goats: Angora, Dairy, and Meat Goats in Temperate & 

Tropical Countries, 1991; 

• Nutrient Requirements of Horses, 1989;

• Nutrient Requirements of Poultry, 1994;

• Nutrient Requirements of Rabbits, 1977;

• Nutrient Requirements of Sheep, 1985; and 

• Nutrient Requirements of Swine, 1998.

As of May 19, 2005 these documents were available for purchase through links at: 

http://www.nap.edu/category.html?id=ag 

Feeding Corn

In the Proceeding of the Symposium on the State of the Science: Animal and Waste 

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

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

Beef Cattle Manure Without Sacrificing Performance". This study found that cattle fed 

high moisture corn instead of dry rolled corn excreted less starch in their manure (starch 

ferments to form volatile fatty acids which are a volatile organic compound) and less 

volatile fatty acids in their manure. Additionally, in the Journal of Dairy Science 

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

Supplemental Phytic Acid on Nitrogen Partitioning in Lactating Cows and Ammonia 
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Emissions from Manure" by Burkholder et al found less starch in the manure of cattle 

fed steam flaked corn than dry ground corn. 

Feed Removal

Research conducted by Dr. Chuck Schmidt at dairies within the SJVAB suggested 

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

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

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

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

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

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

microorganism's activity and thus VOC emissions. 

Weatherproof Storage and Covers for Silage and Grain

Covering silage and grain may minimize the amount of area exposed to the 

environment, thus the amount of area from which VOC in the silage can enter the 

atmosphere. There are various options for covering silage and grain. These include, 

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

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

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

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

information found at the following website: 

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

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

has not been achieved in practice at facilities in the United States, although some 

venders and researchers contend it is feasible. It would be a transfer of technology 

from the composting industry and require significant capital investment (over $100,000 

for materials and installation at a facility with 1,000 cows). 

Leachate Management

Leachate from the silage contains water-soluble VOC. By collecting this and sending it 

to a treatment system, such as an anaerobic digestion lagoon, the owner/operator 

minimizes the opportunity for the water in the leachate to evaporate and the VOC to be 

emitted into the atmosphere. 

Eliminate Silage

Since fermenting processes, such as the process used to produce silage, emit VOC, 

substituting fermented feed (silage) for unfermented feed (grain) would reduce VOC 

emissions. However, due to feed availability and cost, this is considered extremely 

difficult for facilities to implement. This is primarily due to the Regional Water Quality 

Board requirements for land application of animal waste in a manner that minimizes or 
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prevents nitrates and nitrites from entering ground water. One common method to do 

this is planting silage crops, which take in significant quantities of nitrogen, such as 

corn. Therefore, staff believes that implementing this measure would result in 

significant increase in waste treatment costs (over $100,000 for a facility with 1,000 

cows), such as installation of a denitrification system for animal waste; purchase of 

additional land; or transport of animal waste offsite. 

Swine and Poultry Options

Research at the University of Mississippi State University and the International Journal 

of Poultry Science 2(5):313-317, 2003 article titled "Reduction of Broiler House Malodor 

by Direct Feeding of a Lactobacilli Containing Probiotic" by Chang et al suggested that 

feeding broilers lactobacilli containing probiotic reduced VOC emissions from the broiler 

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

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

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

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

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

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

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

Feed additives that improve digestion efficiency have been studied on swine and poultry 

already being fed according to NRC guidelines for protein and nitrogen. In swine, 

research at the University of Purdue demonstrated that the addition of 5% cellulose in 

feed formulation reduced VOC emissions by 11%. The study reported no adverse 

health effects from the addition of this quantity of cellulose (Sutton 1998). The study 

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

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

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

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

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

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

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

and Phenolic Compounds in Pig Manure Through Diet Modification" by Hankins et al 

found the following feed measures reduced volatile fatty acids in swine manure: 

• Feeding probiotics; 

• Feeding at least 5% cellulose in the diet; 

• Feeding a casein based diet; 

• Feeding an amino acid supplemented diet with 2% sucrose thermal 

oligosaccharide caramel; 

• Feeding a diet with no more than 10% crude protein with supplemented lysine, 

threonine, tryptophan, and methionine; and 

• Feeling animals 10 ppm anthraquinone. 
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Since swine and chickens have a different digestive system and nutrient requirements 

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

these feeding strategies would reduce VOC emissions from other types of animals. See 

Figure 1 for a brief explanation of the difference between a ruminant (e.g. cow) stomach 

and a simple stomach (e.g. swine and chickens). 

Figure 1: Ruminants versus Simple Stomach Animals 

 

However, owners/operators of non-swine operations may utilize these options for their 

operation if they satisfy the requirements for utilizing these as alternative mitigation 

measures. 

Alternative Mitigation Measures

The following mitigation measures have been proposed and many are being researched 

as potential VOC mitigation measures. However, at the time of this report, there was 

insufficient data for staff to determine that the measures would result in volatile organic 

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

Carbohydrates Very Little Sugars 

Microbes 

Feed 

HCl 

Pepsin 

Intestinal 

Proteins Enzymes Amino Acids 

Fats VOC 

Carbohydrates 

Proteins 

Fats 

Simple Stomachs (swine, poultry, etc.) 

HCl 

Pepsin 

Intestinal 

Enzymes 

Sugars 

Amino Acids 

VOC 

Source: Rumen Microbiology and Its Role in Ruminant Nutrition by Dr. James Russell. 
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compound (VOC) emission reductions and not cause harm to animals. Stakeholders 

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

to the satisfaction of the ARB, APCO, and EPA that the measure achieves VOC 

reductions that are equal to or exceed the reductions that would be achieved by other 

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

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

removed from the list because staff was unable to locate appropriate standards 

for these practices); 

2. Feeding high moisture or steam flaked corn instead of dry corn to swine; 

3. Feeding high moisture feeds other than corn, instead of dry feed; 

4. Feeding a diet containing probiotics to animals other than swine and poultry; 

5. Feeding a diet supplemented with amino acids to animals other than swine and 

poultry; 

6. Feeding a diet containing at least 5% cellulose to animals other than swine; 

7. Feeding a casein based diet to animals other than swine; 

 8. Feeding an amino acid diet supplemented with sucrose thermal oligosaccharide 

caramel to animals other than swine; 

9. Feeding a diet with no more than 10% crude protein to animals other than 

swine; 

10. Feeding a diet containing 10 ppm anthraquinone to animals other than swine; 

11. Feeding feed additives that reduce feed decomposition for animals other than 

poultry; 

11. Feeding a diet containing liquid instead of solid feed; 

12. Feeding a manure acidifier; 

13. Feeding high moisture or steam flaked corn to swine; 

14. Only feeding silage that has a particle size of 10 to 20 mm; 

 15. Feeding high moisture grain; 

 16. Feeding animals elephant grass (also known as Napier grass and Pennisetum) 

instead of alfalfa hay; 

17. Feeding animals bicarbonate; 

 18. Feeding animals forage instead of grain; 

 19. Supplementing animal diet with ruminally undegradable fiber; 

 20. Feeding a diet containing canola meal; 

 21. Feeding a diet containing sunflower seed; 

 22. Using silage additives such as sodium diacetate; 

 23. Using AIV silage; 

24. Feeding a non-fiber carbohydrate supply to animals; and 

 25. Feeding a diet containing supplemental fats. 
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C. Housing/Animal Waste Mitigation Measures 

Rapid Drying, Rapid Removal of Manure, and Moisture Minimization

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

anaerobic decomposition of manure. Suppression of emissions of reduced gaseous 

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

and increased removal frequency. Increased removal frequency reduces anaerobic 

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

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

needed by the microbes that decompose the manure to form VOC; and moving manure 

and feed from areas with minimal controls to areas with significant controls (such as a 

treatment lagoon) reduces the quantity of uncontrolled manure and feed emissions. 

Elimination of Liquid Manure Handling 

Poultry excrete a white solid called uric acid. Ammonia and VOC are emitted as the uric 

acid breaks down. The microbes needed to degrade the protein in the uric acid require 

moisture; therefore, moisture reduction is a significant means of reducing uric acid 

breakdown and thus ammonia and VOC emissions. Hatfield noted that VOC emissions 

are negligible at poultry scrape facilities, but significant at facilities with liquid handling 

systems. Therefore, using a solid litter handling system exclusively is considered a 

control measure. 

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

solid excretion. Moisture facilitates this mixing process. The microbes that break down 

the waste require moisture, thus drying the waste and employing moisture minimization 

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

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

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

"[m]easured flux was proportional to manure pH and moisture content" (Texas A&M 

University Paper #04-A-646-AWMAA). In the paper titled "Strategies to Reduce Manure 

Emissions," McGinn stated that "[a]dding more than 20 mm of water to manure 

increased volatile fatty acids emissions over a four-day period. Therefore, solely utilizing 

a solid manure handling method for housing would reduce VOC.

Non-manure Based Bedding

As mentioned previously, manure breaks down in the presence of moisture to emit VOC. 

Housing tends to have high humidity and moisture due to misters, animal urination, and 

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

of manure products present in the housing that have the potential to emit VOC. Some 

types of non-manure based bedding are rice straw, almond hulls, cow waterbeds, and 

cow mats. Furthermore, you limit the size of separated solid stockpiles, which emit VOC, 
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on the facilities since in non-manure based bedding only a minimal quantity of separated 

solids is necessary.

Housing Animals in Buildings 

One alternative would be to enclose the animal housing and vent the exhausted air to a 

secondary control device such as a biofilter. Plastic "curtains" similar to those used in 

poultry houses, in addition to traditional wall material, have been used for enclosures 

vented to biofilters. Since all the animal waste and enteric emissions in the house 

would be controlled by venting the exhaust air through a biofilter, management practices 

requirements including, but not limited to, dietary manipulation, animal waste removal 

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

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

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

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

This option alone may achieve highest VOC reductions of all the management practices 

proposed combined. 

Furthermore, enclosing animals in buildings and venting the buildings to a biofilter may 

have benefits beyond air emissions. Depending on the ventilation rate through the 

house animals may breathe fresher and cleaner air since air may be cycled through the 

enclosure at a faster rate than it would be in a free stall or other housing with minimal or 

no mechanical ventilation. Dr. Terry Smith at Mississippi State University housed 

lactating Holsteins in a tunnel ventilated barn with misters and evaporative coolers and 

found an 1.8-2.7 kg/hd/day increase in milk production and 81% decrease in heat stress 

occurrences compared to animals housed in free stalls with fans and misters. 

Additionally, Hauls Dairy in Montana, a 1,100 head facility, found that, by enclosing their 

milkers, they increased their milk production; decreased their calving interval by over a 

month; reduced the number of cattle with symptoms of heat stress; and reduced odor at 

the facility. However, Hauls did note that adequate ventilation is crucial to protecting 

animal health in the building. 

Operations, such as poultry and swine, already typically house animals in enclosures 

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

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

Hector, Minnesota; University of Minnesota swine facility and University of North 

Carolina swine facilities used barn(s) vented to biofilters, which achieve capture and 

control efficiencies of approximately 80% (this is why an 80% capture and control 

efficiency was used in the VOC control options). SRC in Urbana-Champaign, Illinois 

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

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

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

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

biofilter and configuring the biofilter. Cornell University Dairy Facilities Engineering 
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Program has an interactive program to assist in designing and estimating the cost of a 

tunnel ventilated dairy barn. Please refer to the following website for further information: 

www.prodairyfacilities.cornell.edu/TunnelVent/Final_Report.aspx 

However, this would be considered beyond BARCT due to the high cost and the fact 

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

large CAFs by the ARB. 

Thymol

Thymol is plant oil derived from thyme. This compound was tested by Vincent Varel of 

the United States Department of Agriculture, Agricultural Research Service. This was 

applied to the ground at cattle feedlots and swine housing. In multiple studies, thymol 

showed a reduction in volatile fatty acid (VFA) emissions from manure. Thymol causes 

the pH of the manure to drop more rapidly, further inhibiting microbial activity and air 

emissions. In addition to reducing VFA emissions over 50%, it also reduced fecal 

coliform content in the waste. However, these results were from studies conducted for 

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

long-term effects of these oils. 

Due to the fact it has not been used at facilities similar in size to that defined as large 

CAFs by the ARB and is very expensive, staff considered this mitigation measure 

beyond BARCT. 

Lime

Lime has been used by several facilities to minimize moisture. However, it is extremely 

costly and in many cases not feasible due to soil quality and water quality issues. 

Therefore, it is considered beyond BARCT. 

Vacuum Animal Waste and Apply Directly to the Land

While this would minimize emissions by minimizing the moisture in manure and the time 

that it is stored in an uncontrolled manner, it is considered beyond BARCT due to the 

high capital costs of vacuum trucks. 

Use Shade Structures Designed to NRCS Standards

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

shade structures. It would also minimize animal movement, thus the surface area over 

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

thus considered beyond BARCT. 
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Alternative Mitigation Measures

The following mitigation measures have been proposed and many are being researched 

as potential VOC mitigation measures. However, at the time of this report, there was 

insufficient data for staff to determine that the measures would result in volatile organic 

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

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

satisfaction of the ARB, APCO, and EPA, that the measure achieves VOC reductions 

that are equal to or exceed the reductions that would be achieved by other mitigation 

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

1. Acidification of manure; 

2. Use of manure additives not listed in Proposed Rule 4570; 

3. Use of potassium permanganate in manure piles or corral; 

4. Use fresh water to clean the freestalls; 

5. Use low biochemical oxygen demand water to clean the freestalls; 

6. Use environmentally safe cleaning on degreasing products on dairy manure; 

7. Pave feedlanes at least 8 feet on the corral side of the fence; and 

8. Use of eugenol (may have water quality issues). 

D. Solid Manure Handling

Cover or Eliminate Solid Manure Piles During the Wet Season

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

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

also minimize VOC emissions. 

 

Compost

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

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

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

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

storage may account for approximately three (3) percent on the emissions at a facility. 

Based on this estimate ASPs, in-vessel, and within vessel technologies may reduce 

emission on a facility by approximately 0.69%-2.85%. 

In ASP composting, manure is mixed with other material and formed into piles that are 

mechanically aerated. There are two common methods of aeration- either the compost 

pile is formed over a concrete floor with built-in vents to force air through the compost or 

the pile is formed around pipes attached to a blower that forces air through the pile. 

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

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

as a biofilter. 

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

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

Chapter 3.1, Articles 1-4, may limit the materials that may be use for composting and/or 

place additional requirements on the facility depending on the type of material used in 

composting; origin of material used in composting, quantity of material used; and 

quantity of compost given away or sold annually. 

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

beyond BARCT. 

Solid Waste Digesters

Anaerobic digestion has been used on swine and dairy operations for solid and liquid 

waste handling. Limited preliminary research suggests that when the gas is captured 

and vented to a secondary control, up to 90% control efficiency of VOC emissions from 

the waste can be achieved from these technologies. However, these are extremely 

costly and producers note that they require significant technical skill to operate, thus 

considered beyond BARCT. 

Alternative Mitigation Measures

The following mitigation measures have been proposed and many are being researched 

as potential VOC mitigation measures. However, at the time of this report, there was 

insufficient data for staff to determine that the measures would result in volatile organic 

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

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

satisfaction of the ARB, APCO, and EPA, that the measure achieves VOC reductions 

that are equal to or exceed the reductions that would be achieved by other mitigation 

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

1. Thermal Conversion (Including Combustion and Gasification 

 Technologies that burn waste to produce energy or treat waste to produce fuels 

are classified as "thermal conversion": and include direct combustion (burning 

with excess air to produce heat), pyrolysis (thermal treatment in the absence of 

air, resulting in the production of pyrolysis oil and low BTU gas), gasification 

(thermal treatment at higher temperatures in an oxygen-restricted environment to 

produce a low to medium BTU gas), and hydrothermal liquefaction (thermal 

conversion of solids in a liquid stream to oils and char for separation and use as 

fuel). Many existing thermal conversion technologies are not suitable for raw 

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

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

University of Southern Illinois is testing this potential control option. 

2. Windrow Composting with Management Practices 

 Some stakeholders have suggesting management practices such as controlling 

the moisture content, carbon to nitrogen content, and porosity of compost piles to 

minimize VOC emissions from compost piles. As of the date of this report staff 

was not able to find significant information specifying the appropriate parameters 

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

emission reductions 

E. Solid Separators 

Solid separators may be used to reduce loading of the lagoon, extract separated solids 

for composting and/or bedding, and serve other purposes on the facility. There are two 

categories of solid separation systems-- source separation systems and delayed 

separation systems. While solid separation can occur at any point during manure 

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

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

after the manure has been diluted or stored. 

Belt separation is one the most common types of source separation. Conveyor belts 

are placed beneath the animals, typically under a slatted floor. The belt is concave or 

positioned at an angle allowing the urine to flow into a gutter and away from the solids 

dropping onto the belt. The liquids flow down the gutter by gravity and into a collection 

tank. The manure solids are scraped off the belt and into a separation collection area. 

Belt systems have been used in poultry operations for about 30 years (van Kempen, 

2003), have a life expectancy of eight to ten years, and require minimal maintenance. 

They have also been used routinely in swine facilities. 

The alternative to source separation is delayed separation, separation after the urine 

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

chemical are the main types of solid separation. 

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

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

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

pipes between these two regions or by overflow where the liquid, when it reaches a 

certain height, simply flows over a small dam into another basin. Gravity systems can 

be settling channels, settling basins, or settling ponds. All of these systems require 

additional storage for the separated liquid, as well as periodic removal of the settled 

solids. Current research suggests a solid removal efficiency of 7% to 65% depending 

on factors such as the initial quantity of solids in the waste and the retention time. 
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An alternative to gravity separation is mechanical separation. This relies on a 

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

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

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

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

maintenance required of moving gears. 

Mechanical systems include sloping stationary screens, vibrating screens, screw 

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

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

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

vertical. As the slurry moves down the slope, free liquid flows through the perforations. 

The relationship between efficiency and mesh size is inverse. Vibrating screen systems 

are the second most common mechanical method for solid separation. They are similar 

to the sloping screen, except they vibrate to keep the perforations clear and shake 

solids off the edge of the screen. A different mechanical system is the screw press. 

The slurry enters a hopper, and then the screw press, which consists of a screw auger 

rotating inside of a cylindrical perforated screen. The slurry is put under pressure by the 

auger as it moves toward the discharge end. Adjusting a counterweight at the 

discharge end of the system can alter the efficiency of solid separation. Another system 

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

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

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

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

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

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

the slurry moves under the rollers, more liquid is squeezed out. Solids are scrapped off 

the drum and roller apparatus and into a storage container. Another method is a 

centrifuge where the centrifuge rapidly spins the slurry, pulling the liquids to the outside 

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

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

types of solid separators as shown in Table 13. 
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Table 13 

Estimates of Solid Removal with Mechanical Separation Methods 

Percent Removal Source 

10%-98% Separating Fact from Fiction, Alan Newport, Hay and Forage 

Grower, Sept. 2004. 

15%-65% Iowa State University, Selection and Performance of 

mechanical Solid-Liquid Separators, Robert T. Burns, 

rburns@iastate.edu. 

17%-60% University of Tenn., Performance Testing of Screw-Press 

Solid Separators, Robert Burns and Lara Moody, P.O Box 

1071, Knoxville, TN 37901-1071. 

30%-40% University of Ill. at Urbana-Champaign, Swine Odor Waste 

Management Paper 4, 2005. 

50%-70% Miner 2002. 

Several factors including the size of the separation screen (which typically range from 

0.010-0.150 inch and may be as small as 0.007 inches or as large as 0.025 inches); 

and initial solid concentration of the manure can affect the solid removal efficiency 

F. Liquid Manure Mitigation Measures 

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

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

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

conditions, complex organic compounds are degraded microbially to volatile organic 

acids and other volatile organic compounds, which in turn are converted to methane 

and carbon dioxide by methanogenic bacteria. When the activity of the methanogenic 

bacteria is not inhibited, virtually all of the VOC are metabolized to simpler compounds 

and the potential for VOC emissions is nominal. However, inhibition of methane 

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

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

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

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

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

sites. (EPA 2001) 

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

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

thus VOC emissions from the lagoon will be less. 

Phototrophic Lagoon

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

nmol mL-1, phototrophic lagoons, showed lower emissions of VOC than other swine 
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management systems. Overall, a lagoon with a phototrophic lagoon had 80% to 90% 

less VOC emissions per head on the average than a lagoon that was not phototrophic 

(Zahn 2001). Reductions of 80% to 93% of VOC were also observed in phototrophic 

swine lagoons following a photosynthetic bloom according Do 2003. 

 

Lagoons Designed In Accordance with USDA/NRCS Recommendations

The USDA NRCS Agricultural Waste Management Field Handbook offers guidance on 

building and designing anaerobic and aerobic lagoons. In general, lagoons that meet 

the guidance parameters are expected to have lower VOC emissions than lagoons with 

smaller dimensions, lower dissolved oxygen content, or higher loading. In general, 

aerobic lagoons are shallow, 2-5 feet deep and loaded so that the dissolved oxygen 

concentration is approximately double the biological oxygen demand. Anaerobic 

lagoons tend to be sized so that there is sufficient water to dilute the animal waste 

entering the lagoon such that there is no more than 11 pounds of volatile solids per 

1,000 feet3

 per day entering the lagoon. If the lagoon does not have sufficient volume 

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

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

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

be handled similar to other solids on the facility and the liquid, with less volatile solids, 

would be sent to the lagoon. 

Lagoon pH

The solubility of VOC is pH dependant, thus measures to maintain the pH within the 

range that maximizes VOC solubility would minimize VOC emissions. 

Complete Aeration/Aerobic Lagoons

In this system, sufficient concentration of dissolved oxygen is maintained to enable 

aerobic digestion to occur. Aerobic digestion is the decomposition of organic 

compounds by microbes in an oxygen-rich environment. The microbes reduce the 

organic compounds in the waste to carbon dioxide, water, nitrates, sulfates, and 

biomass (sludge). According to Dr. Ruihong Zhang of UC Davis, complete aeration can 

be achieved with dissolved oxygen concentrations of greater than 2.0 mg/L. However, 

this has not been achieved in practice at CAFs in the SJVAB and consumes significant 

energy, thus is considered beyond BARCT. 

Lagoon Loading

This measure would minimize VOC by promoting phototrophic conditions, however is 

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

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

parameters. 
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Use Non-standard Equipment or Chemical Additives with the Solid Separator

This method requires extensive capital expense and is typically beyond what is utilized 

at CAFs, therefore considered beyond BARCT. 

Covered Lagoon with Gas Vented to a Control Device

Covers may be used to capture the gas produced by reactions in the lagoon and send 

the gas to a secondary VOC control device, which includes, but is not limited to an 

anaerobic digester generating electricity. Storage covers need to be acceptable by 

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

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

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

so that mosquito abatement personnel can treat the lagoon if needed. There are two 

main storage cover designs: bank-to-bank and balloon. 

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

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

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

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

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

free of standing water. This design can create an anaerobic environment, depending on 

the specific design and materials used. 

A variation of the bank-to-bank cover design is the balloon cover. These are essentially 

fabric pulled over the surface of the storage facility and kept aloft with fans and blowers. 

The fans and blowers create air pressure to inflate the cover. Pre-cast concrete posts or 

stainless steel poles may be used as supports for the cover. A matrix of ropes placed on 

the manure may also be used to keep the cover from sinking into the manure in case of a 

power loss. These covers are typically not appropriate for creating anaerobic conditions 

since air is pumped into the headspace above the manure. Once again, the edges of the 

cover are buried in trenches around the perimeter of the lagoon. There are various 

materials that may be used for covers including, but not limited to hypalon 45, polyvinyl 

chloride (PVC), PVC coated with acrylic or hypalon, estane polyurethane, polyethylene, 

and others. 

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

Alternative Mitigation Measures:

The following mitigation measures have been proposed and many are being researched 

as potential VOC mitigation measures. However, at the time of this report, there was 

insufficient data for staff to determine that the measures would result in volatile organic 

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

utilize these methods to comply with rule requirements if they demonstrate, to the 
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satisfaction of the ARB, APCO, and EPA, that the measure achieves VOC reductions that 

are equal to or exceed the reductions that would be achieved by other mitigation 

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

1. Chemical Oxidation 

 Chemical oxidants can be applied in liquid form to liquid manure systems to 

oxidize VOC. Agents such as potassium permanganate and hydrogen peroxide 

may be applied to the system, at the surface, to reduce emissions. However, a 

large amount of these types of additives is typically required due to the high 

organic matter content of animal manure. The emission reductions achieved by 

these additives also appears to be short term, requiring frequent applications to 

consistently reduce gaseous emissions. There are several venders of these 

chemical oxidants and these chemicals have been utilized on swine and dairy 

facilities, however, due to the cost and other concerns, their use is not 

widespread. 

2. Ozonation 

 Ozone has been used to reduce gaseous emissions from manure slurries by 

bubbling or diffusing it through dairy slurry. However, ozone must be produced 

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

3. Microaerobic Biological Nutrient Management Practice 

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

is pumped through a contact chamber and then a coarse solid separator. The 

clarified liquid fraction containing dissolved solids, suspended solids, and a 

suspension of microbial cells flows to the next unit process in the treatment 

systems, the bioreactor. The liquid then passes through anaerobic and anoxic

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

precursors are metabolized and incorporated into microbial biomass. Based on 

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

efficiency of approximately 79% for the emissions from liquid manure handling 

and approximately 52% for emissions from land application. The District has 

reviewed the provided information about this technology and it appears that it has 

the potential of reducing VOC emissions. Additional information, such as that 

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

system. CAF owners/operators would include the additional information should 

they wish to propose such systems as alternative mitigation measures under 

Section 5.0 of Rule 4570. 

4. Microbial Lagoon Additives 

 In this method a mixture of microbes and, in some cases, nutrients and/or media 

are added to the lagoons on a routine basis. Venders suggest that this 

technology reduces VOC emissions, manure sludge buildup, odors, preserves 

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

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

VOC emissions. 

5. Aquatic Cropping 

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

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

into their biomass. The algae could then be harvested and used as a slow 

release fertilize; protein feed; component in make-up production; or other use. 

6. Natural Crust Manure Storage Cover 

 A manure crust typically forms if large amounts of solids are added to a liquid 

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

that would reduce VOC emissions. Others believe that by increasing solid 

loading to form this crust one would increase VOC emissions. 

7. Elimination of Processing Pit 

 Some believe that the processing pit is an additional emission unit that causes 

increase VOC emissions. They note that the manure in this pit is not treated; the 

pit has solids levels above 1%; in some cases the pit is stirred; and the solids 

have a potential of settling and forming anaerobic conditions—all of which could 

lead to increased VOC emissions. Others believe that the processing pit is not 

an additional emission unit and explain it as simply an expanded use of the pump 

pit for the solid separator. 

8. Wet Combustion System 

 This process involves adding oxygen and bacteria. The technology introduces 

oxygen into pond systems with the intent of raising the oxygen levels. Bacterial 

is introduced on a daily basis. 

9. Reciprocating Water Technology 

 In this process, organic matter is oxidized and nitrogen is removed via biological 

nitrification and denitrification. 

10. Rotating Biological Contactor 

 In this process, a fixed film of microorganisms rotates, much like a water wheel, 

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

alternating aerobic and anaerobic conditions. Organic compounds are oxidized. 

G. Crop Application 

Land Application

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

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

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

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

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

has already by treated or with low moisture content, VOC emitted by biological 

degradation of manure is minimized. 

Land application at an agronomic rate can be a cost-effective and sustainable practice 

that can build soil tilth, increase the water holding capacity of the soil, and provide 

essential nutrients for plant growth. The land application options are designed to 

provide and ensure maximum rule flexibility and allow land application of animal waste. 

Nothing in the rule places minimal or maximum limits on the quantity of manure applied 

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

land apply waste, either by timing of animal housing removal or only applying waste that 

has been treated or with dried.

It is understood that a balance between manure incorporation and conservation tilling 

must be struck-- incorporation disturbs the soil surface and reduces plant residue cover, 

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

It is further understood that these measures are not always feasible, for example once 

crops grow a certain height the use of injection equipment may cause crop damage--

therefore injection methods are not to be used at these times. Additionally, in wet 

weather the vehicles used to transport the manure could become stuck in the fields, 

thus at some times weather may cause this option to be infeasible. In such cases, 

farmers would likely choose the following mitigation measures: 

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

would be required; 

• Not apply liquid manure; 

• Only apply solid manure with moisture content less than 50%, thus no tilling 

would be required; or 

• Not apply solid manure. 

Surface applied solid and slurry type manure may be incorporated into the soil by either 

disking or plowing. Liquid manure may also be injected using a mobile injection device 

attached to a tank. Incorporation is expected to reduce VOC emissions because the 

soil is expected to trap the VOC below the surface and act a biofilter scrubbing and 

absorbing a significant portion of the VOC before they are able to escape into the 

atmosphere. 

H. Secondary Controls 

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

VOC from the air stream. Air from composting, digesters, enclosures, and covered 

lagoons, as discussed previously in this staff report, may be vented to a secondary 

control device including, but not limited to, biofilters and wet scrubbers. These systems 
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have routinely been used in the swine industry and as well as some poultry and dairy 

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

for VOC control. 

Biofilter

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

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

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

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

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

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

empty space underneath the biofilter. A fan then pushes the air up through the biofilter 

material. In the media, microbes convert VOC to carbon dioxide and water. Figure 2 

below depicts an open-faced biofilter system for a swine house. 

Figure 2 Biofilter 

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

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

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

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

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

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

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

Livestock House. Some building ventilation rates are shown in Table 14. 
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Table 14 

Typical Building Airflow Requirements 

Facility Type 

Airflow Requirements 

(cubic feet per minute per animal 

space for warm weather) 

Swine Nursery 35 

Swine Finishing 120 

Swine Gestation 150 

Swine Farrowing 500 

Broiler or Layer (5 lb live weight) 5 

Turkey (40 lb) 32 

Dairy Cow (1,400 lb) 470 

Covered Manure Storage (per square foot 

of surface area) 

0.1 

(Source: Schmidt 2004) 

Biofilters treating air from a manure storage unit may treat a smaller volume of air than 

animal housing, but the air will have a higher concentration of odorous gases. Typical 

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

surface area. 

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

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

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

A proven organic media mixture for animal agriculture biofilters ranges from 

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

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

microorganisms, nutrients, and moisture holding capacity. 

The life of the media is typically at least three years and likely five years or longer. 

During this time, the media decomposes and becomes denser, which reduces the 

porosity (air space in the media) and increases the pressure or force needed to move 

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

A static pressure drop of over 50% of the design pressure, the pressure upon initial 

start-up, across the biofilter indicates the need to replace the media. (Schmidt 2004) 

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

must be constructed to move the air from the fans to the plenum of the biofilter. The 

ducts and plenum should be designed to keep the air velocity between 600 and 1,000 

feet per minute. (Schmidt 2004) 

Moisture control is also essential. Inadequate moisture can allow the media to dry out, 

deactivating the microbes and creating cracks and channeling of air, which results in a 

reduction of filter efficiency. Too much moisture can plug some of the pore in the 
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media, causing channeling and limiting oxygen flow in saturated areas of the filter, 

thereby creating anaerobic zones in the biofilm. Recommended moisture content for 

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

2004.) 

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

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

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

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

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

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

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

through the media and being completely treated by the microbes. 

Gas Absorption

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

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

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

water is used as the scrubbing media in many applications, the absorption of gases can 

be enhanced using chemical reactions between target gases and the absorbing media, 

such as using caustic solution to remove acidic gases. Some negative impacts 

associated with this option are the emissions from the generation of the electricity 

needed to convey air to the scrubber and disposal of the absorbing media. It has been 

used in a study at the University of Minnesota, however staff was unable to find 

commercial CAFs utilizing this technology to reduce VOC. 

Bioscrubber

The concept behind a bioscrubber is similar to that of biofiltration with the exception of 

the microorganisms, which are housed in an enclosed packed tower with water 

circulated counter-current to the incoming building air, instead of in a filter bed. As 

contaminated air is passed through the scrubber, water-soluble compounds are 

absorbed by the water and oxidized microbially. Some scrubber designs contain a 

vessel that is used as a biological reactor. Effluent from the scrubber is routed to the 

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

information was found in the literature review regarding the ultimate disposal of the 

effluent from bioscrubbers. However, it is likely that this effluent could be land applied. 

Periodically the filter media must be replaced due to decomposition and compaction. 

These have been utilized at swine operations with a reduction of over 80%, however 

they are not common at commercial operations. 
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IV. MONITORING AND MEASUREMENT REQUIREMENTS (MMR) 

The monitoring and measurement requirements, which include minimum testing 

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

ensuring that adequate testing is conducted to demonstrate compliance with the 

appropriate mitigation measures and such measures are operating in a manner that 

optimizes the VOC reductions. 

Monitoring Requirements

The CH&SC 40724.6 requires that the District obtain sufficient information to develop an 

emission inventory for all pollutants. Since the emission inventory is dependent on the 

number of animals in the SJVAB and typically other agencies do not collect and publish 

data in sufficient detail (e.g. number of animals of each type in each county) to 

accomplish this, staff is requiring producers to provide this information to the District, 

upon request. Please note that owners may use documents, such as Regional Water 

Quality Board Waste Nutrient Management Plans that list the numbers of animals in 

each production group (e.g. calves, heifers, milkers, and dry cows) to comply with this 

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

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

Other monitoring and testing requirements only apply to facilities that choose mitigation 

measures where such monitoring or testing would assist in demonstrating compliance. 

This is to acknowledge that, based on currently available information, these parameters 

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

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

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

Feed Mitigation Measures for Dairies

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

mitigation measures: 

Class One Mitigation Measures 

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

2. a. Feed animals high moisture corn or steam-flaked corn and not feed 

animals dry rolled corn. 

3. a. At least once every fourteen (14) days remove feed from the area 

where animals stand to eat feed. 

4. a. At least once every fourteen (14) days remove spilled feed from the 

area where equipment travels to place feed in the feed bunk. 

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

hours of a rain event. 

6. a. Feed or dispose of rations within forty-eight (48) hours of grinding and 

mixing rations. 

7. a. Store grain in a weatherproof storage structure from October through 

May. 

8. a. Implement an alternative mitigation measure(s), not listed above. 

Facilities only choosing options A3, A4, A5, and A6 would not need to maintain records 

of feed content, formulation, or quantity of feed additives used in order to demonstrate 

rule compliance since these measures are not affected by this. However, a facility 

choosing option A1 may need to maintain the aforementioned records in order to 

demonstrate compliance. 

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

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

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

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

parameters which are not expect to change significantly in time periods of less than a 

year. An example would be a biofilter. If the blowers are operating at a specific 

pressure, unless the biofilter media has been saturated, it has been well documented 

that specific VOC control efficiencies will be achieved. On the average, biofilter media 

becomes saturated to the point it is not effective for VOC control in one (1) to ten (10) 

years, depending on design. Therefore, testing more than once a year is not 

considered vital to ensure VOC control. Please note that a VOC control device, as 

defined in Proposed Rule 4570, are devices that capture air; reduce the VOC content in 

the air; and release the air into the environment. This would be a system such as an 

enclosure vented to a biofilter. It would not include control measures, such an 

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

measure. 
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Staff acknowledges that, at this time, there is not substantial information to determine 

what constitute minimum testing frequency to ensure compliance with the mitigation 

measures specified in the rule. However, staff believes that the minimum testing 

frequency for control devices, as was done for control devices in other District 

prohibitory rules is twelve (12) months. Also, as noted in the rule, more frequent testing 

may initially be necessary to confirm rule compliance. The need for more frequent 

testing would be determined by the APCO, ARB, and EPA and may only be temporary 

until the owner/operators has demonstrated that system tested (e.g. lagoon with a ph 

between 6.5 and 7.0) is stable. 

V. POTENTIAL FUNDING SOURCES 

As noted in the cost-effectiveness and socioeconomic analysis, some of these controls 

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

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

are listed below. 

A. National Programs 

Environmental Quality Incentive Program (EQIP)

This program provides financial and technical assistance to install or implement 

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

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

things. Approximately 60% of the total EQUIP funds are target to projects involving 

animal agriculture and air quality is one of the four national priorities for this program. 

This funding can be used for up to approximately 75% of the cost of the project and has 

a maximum funding per project of approximately $450,000. For more information 

please contact your local or state Natural Resource Conservation (NRCS) office or 

check their website at http://www.nrcs.usda.gov/programs/eqip/index.html. 

EQIP Conservation Innovation Grants Program

This program is intended to accelerate technology transfer and adoption of promising 

technologies and approaches to address some of the nation's most pressing natural 

resource concerns. 

This funding can be used for up to approximately 50% of the cost of the project. For 

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

each year, and the website at http://www.nrcs.usda.gov/programs/cig/. 
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Renewable Energy Systems and Energy Efficiency Improvement Program

This program establishes grant, loan, and loan guarantee programs to assist farmers, 

ranchers, and rural small businesses in purchasing renewable energy systems for 

making energy efficiency improvements. 

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

more information look for the announcement or check their website at 

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

Sustainable Agriculture Research and Education Grants Program

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

environmentally sound, and good for communities. 

For more information look for the announcement or check their website at 

http://www.sare.org/grants/index.htm. 

B. State Programs 

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

areas of the state. 

Section 319 Grants

These may fund anaerobic digesters, manure vacuum devices, solid separators, 

compost devices and feed management practices. For more information please check 

their website at http://www.swrc.ca.gov/funding/319h.html 

Self Generation Incentive Program

This may fund up anaerobic digesters. For more information check their website at 

http://www.sdenergy.org/ContentPage.asp?ContentID=35&SectionID=24. 

Energy Efficiency Improvement Loan Fund

This may fund anaerobic digesters. For more information check their website at 

http://www.safe-bidco.com 

VI. PROPOSED RULE 4570 (CONFINED ANIMAL FACILITIES) 

The purpose of Proposed Rule 4570 is to limit VOC emissions from confined animal 

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

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

complying with the rule's control requirements, the rule includes several options for 

compliance and the option for owner/operators to develop their own control measures 

as appropriate. 

A. Summary of Proposed Rule

Section 1.0 Purpose 

The purpose is to limit volatile organic compound (VOC) emissions from confined 

animal facilities (CAF). 

Section 2.0 Applicability

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

Section 3.0 Definitions 

Lists general definitions that pertain to the rule. 

Section 4.0 Exemptions 

The rule exempts facilities not exceeding any of the thresholds listed in Table 16 from 

all requirements except those requiring records be kept demonstrating that they qualify 

for the exemption. 

Table 16: Exemption Thresholds

Livestock Category Number of Animals 

Dairy 1,000 lactating cows 

Beef Feedlots 3,500 beef cattle 

Other Cattle Operations 7,500 cows 

Chickens 650,000 

Ducks 650,000 

Turkeys 100,000 

Swine 3,000 

Horses 2,500 

Sheep, Goats, or any combination of the two 15,000 

Any other livestock not listed above 30,000 

Section 5.0 Requirements 

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

measures from the measures listed in the rule for each emission area on their 

facility. This cafeteria plan provides flexibility to facilities considering that CAF 

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

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

required number of measures have the option of developing VOC mitigation 

measures that are more applicable to their facilities by demonstrating the 

efficiency of the measures. 
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 Additionally, facilities have the option of submitting an emission mitigation plan that 

demonstrates a facility wide VOC reductions of at least 30% in lieu of implementing 

the minimum required number of measures in the applicable Tables 1 through 6 of 

the rule. The mitigation measures specified in Tables 1 through 6 of the rule are 

considered to have been approved by the APCO, ARB, and EPA through the 

rulemaking process, which provided avenues for such approving authorities to 

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

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

wide emissions reduction by calculating the control efficiencies of their selected 

mitigation measures in accordance with the procedures/methods shown in Appendix 

B of the Final Draft Staff Report for Rule 4570. Any mitigation measure in the 

emission mitigation plan that is not specifically listed in the rule is considered an 

alternative mitigation measure. As such, it is subject to the requirements for 

alternative mitigation measures, as defined in Section 3.0 of the rule, including the 

requirement that the mitigation measure be approved by the ARB, APCO, and EPA. 

It is important to note that alternate mitigation measures are evaluated on a case-bycase basis and will only be approved by the APCO, ARB, and EPA if such alternate 

measures have been determined to achieve reductions that are equal to or greater 

than the reductions that would be achieved by those specific measures listed in the 

Tables 1 through 6 of the rule. 

Additionally, Section 6.1.6 of the rule specifies that the permit application, including 

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

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

the opportunity to view the emission mitigation plan, approve or disapprove of the 

plan, and recommend changes, as appropriate. 

Table 17 

Summary of the Minimum Number of VOC Mitigation Measures Per Animal 

Type and Area Compared to Total Number of Options 

Area Dairy Beef Other Cattle Swine Poultry 

Feed 4 of 8 5 of 8 5 of 8 5 of 12 5 of 10 

Silage 1 of 6 1 of 6 1 of 6 0 of 0 0 of 0 

Milk Parlor 1of 3 0 of 0 0 of 0 0 of 0 0 of 0 

Housing 8 of 26 7 of 15 7 of 23 5 of 10 4 of 17 

Solid Manure 2 of 8 1 of 8 1 of 8 1 of 8 1 of 8 

Liquid Manure 1 of 11 1 of 11 1 of 11 1 of 11 1 of 11 

Land Application 2 of 7 2 of 7 2 of 7 2 of 7 0 of 0 

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

• Suspension of Mitigation Measures

This section allows mitigation measures to be suspended in order to promote 

molting; protect animal health; and address quarantine situations. In some 

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

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

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

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

licensed veterinarians, nutritionists, and government employees. Except for 

poultry molting, the exemption is designed to address atypical, non-periodic, 

and rare occurrences, not routine situations. 

Furthermore, to minimize uncontrolled emissions, facility will have no more 

than 30 days to address the issue requiring the measures to be suspended or 

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

designed to minimize the time that any VOC emissions occur in an 

uncontrolled manner.

Section 6.0 Permit Requirements 

• Owner/operators would need to submit a permit application for each CAF within six 

(6) months of rule adoption. 

• Permit application has to include: 

• Contact and legal information; 

• List of mitigation measures to be implemented; 

• Animal inventory; and 

• All information necessary for the District to prepare an emission inventory of all 

regulated air pollutants emitted from the facility. 

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

once every three (3) years. 

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

receipt. 

Section 7.0 Administrative Requirements 

• Recordkeeping 

• Indicates recordkeeping requirements 

• Compliance testing 

• Control devices would need to be initially source tested upon start-up or 

modification, and thereafter at least once every 12 months 

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

compliance 

• Test Methods 

• Indicates the applicable test methods to be used in determining compliance 

with the rule requirements. 

Section 8.0 Compliance Schedule 

• Owners/operators would need to comply with all requirements on and after one 

year from the permit issuance date. 
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VII. EMISSION REDUCTIONS 

Emissions Reduction Analysis 

The VOC reductions required by the Extreme Ozone Plan for Proposed Rule 4570 is 

5,767 tons per year (15.8 tons per day) or 25% from the planning baseline of 23,031 

tons of VOC per year (63.1 tons per day). District staff estimated that the VOC 

reduction from Proposed Rule 4570 is about 7,563 tons per year (21 tons per day) or 28 

percent of the total CAF baseline emission of 27,000 tons per year. The VOC emission 

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

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

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

therefore not the pollutant targeted by the District’s Ozone Plan. Although ammonia is 

not specifically regulated by Proposed Rule 4570, the VOC mitigation measures of the 

proposed rule actually have the added air quality benefit of reducing ammonia 

emissions. Staff estimated at least 100 tons per day of ammonia reductions could be 

achieved from the implementation the proposed VOC mitigation measures. The 

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

VIII. HEALTH EFFECTS 

Respiratory diseases associated with agriculture were one of the first-recognized 

occupational hazards. According to the Institute for Agriculture and Trade Policy 

(Wallinga 2004), studies at beef, swine, and poultry facilities show increased 

occurrences of asthma, sinusitis, bronchitis, decreased lung function, and depression 

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

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

are known airway irritants; chronic irritation can permanently scar lungs and lead to 

respiratory problems. (Wallinga 2004) 

 

IX. RULE DEVELOPMENT PROCESS 

As part of the rule development process, District staff conducted public scoping 

meetings in April 2005, public workshops and Socioeconomic Focus Group meeting in 

March 2006 in order to present, discuss, and solicit comments on Proposed Rule 4570. 

In addition to the workshops, staff met with representatives of the beef, dairy, poultry, 

swine industries, and control technology vendors to receive comments on the technical 

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

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

Environmental Protection Agency during the public workshop process and technical 

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

Draft Staff Report.

Proposed Rule 4570 and the Final Draft Staff Report including the analyses mandated 

by CH&SC will be published prior to a public hearing on June 15, 2006 for the District 

Governing Board to consider the adoption of the proposed rule. The notice of the public 

hearing for this rule project was published in a general circulation newspaper in each of 

the eight San Joaquin Valley counties, and will be mailed to affected sources and 

interested parties. The public notice solicited written comments to be submitted by mail, 

and will identify the name and telephone numbers of the District staff that can answer 

questions and respond to comments. The June 15, 2006 adoption schedule will satisfy 

the requirement of the CH&SC for the District to adopt a regulation by July 1, 2006. 

X. COST EFFECTIVENESS ANALYSIS 

Pursuant to CH&SC 40920.6(a) a cost effectiveness analysis is required to be 

performed for rules that implement BARCT. For the purpose of calculating the 

compliance cost and associated cost-effectiveness of the proposed rule, staff took into 

consideration those mitigation measures already being implemented at facilities and 

assumed that owners/operators will likely choose the lowest cost mitigation measures. 

This was done to minimize overestimation of compliance costs. A detailed discussion of 

the analysis is shown in Appendix C of the Final Draft Staff Report. The estimated cost 

effectiveness is as follows: 

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

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

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

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

A cost effective analysis was not done for poultry because, based on comments from 

industry and information in the District’s permit database, staff has determined that 

existing poultry facilities are already required to implement best available retrofit control 

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

considered minimal and typically not included in the cost effectiveness analysis. 

XI. SOCIOECONOMIC ANALYSIS 

Pursuant to CH&SC 40728.5, the District is required to perform a socioeconomic impact 

analysis prior to the adoption, amendment, or repeal of a rule that significantly affects 

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

presented in Appendix D of the Final Draft Staff Report. 
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XII. ENVIRONMENTAL IMPACTS 

Proposed Rule 4570 underwent an environmental review in accordance with the 

requirements of the California Environmental Quality Act (CEQA). A proposed negative 

declaration has been issued by the District and made available for public review. The 

public commenting period ended on May 29, 2006. Staff received comments on the 

proposed negative declaration from the State Water Resources Control Board and 

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

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

recommends that the District Governing Board approve the negative declaration. 

XIII. RULE CONSISTENCY ANALYSIS 

Pursuant to California Health & Safety Code Section 40727.2, District staff prepared a 

rule consistency analysis that compares the elements of Proposed Rule 4570 with the 

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

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

Appendix E of the Final Draft Staff Report. 

XIV. REFERENCES 

1. APCO BACT Determination and Dairy Permitting Advisory Group material 

available at http://www.valleyair.org/busind/pto/dpag/dpag_idx.htm. 

2. ARB, Staff Report to Consider Large CAF Definition, May 2005, 

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

3. Archibeque, S.L., Freetly, H.C., Miller, D.N., Ferrell, C.L. 2005, Feeding High 

Moisture Corn Instead Of Dry Rolled Corn Reduces Odor Production In Finishing 

Beef Cattle Manure Without Sacrificing Performance, Proceedings of The 

Symposium on the State of the Science Animal Manure and Waste Management, 

January 5-7, 2005, San Antonio, Texas, 2005. 

4. Bicudo, J.R. et. al., Managing Manure Solids Dairy Manure Systems: Equipment 

and Technology, Natural Resource, Agriculture, and Engineering Service NRAES143, Cornell University, 2001, http://www.nraes.org/publications/nraes143.html. 

5. California Health and Safety Code 42310, 39011.5, 39023.3, 40724, 40731, 

407301, 42301, 44559, et al, http://www.leginfo.ca.gov. 

6. Danesh, S.D. et al, Pilot Plant Demonstration of a Three-Stage Waste Treatment 

Technology, DGH Engineering LTD, 2000, 

http://www.manure.mb.ca/projects/completed/pdf/98-01-31-three-stage-wastetreatment.pdf. 
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7. Do, Young et. al., Role of Rhodobacter sp. Strain PS9, a Purple Non-Sulfur 

Photosynthetic Bacterium Isolated from an Anaerobic Bacterium Isolated from an 

Anaerobic Swine Waste Lagoon in Odor Remediation, Applied and Environmental 

Microbiology, Vol 69(3) 1710-1720, March 2003, 

http://aem.org/cgi/content/full/69/3/1710. 

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

Operations, August 15, 2001. 

9. Gilley, J.D. et. al., Phototrophic Anaerobic Lagoons as Affected by Copper and 

Zinc in Swine Diets, Transaction of the ASAE, 43(6):1853-1859. 

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

Engineering Cornell University, Spring 2000, 1999. 

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

Livestock Agriculture, Journal of the Science of Food and Agriculture, 84:1414-

1420, 2004, http://www.valleyair.org/busind/pto/dpag. 

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

13. Miner, J.R. et al, Managing Livestock Wastes to Preserve Environmental Quality, 

Iowa State University Press, 2000. 

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

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

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

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

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

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

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

17. SCAQMD support documents for Rules 1127 and 1133, on links at 

http://www.aqmd.gov/rules/support.html. 

18. Schmidt, C.E. et. al., Assessment of Reactive Organic Gases and Amines from a 

Northern California Dairy using the USEPA Surface Emission Isolation Flux 

Chamber, ARB Research Symposium, 2005, 

fttp://ftp.arb.ca.gov/carbis/ag/agadvisory/schmidt05jan26.pdf. 

19. Wallinga, David, MD, "Concentrated Animal Feeding Operations: Health Risks to 

Farmers and Workers", Institute for Agriculture and Trade Policy, October, 2004. 
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