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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-1 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

APPENDIX E 

ANALYSIS OF CLASS TWO MITIGATION MEASURES FOR 

REVISED PROPOSED AMENDMENTS TO 

RULE 4570 (CONFINED ANIMAL FACILITIES) 

October 21, 2010 
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APPENDIX E 

COST ANALYSIS OF CLASS TWO MITIGATION MEASURES 

I. INTRODUCTION 

Rule 4570 contains options for facilities to implement certain “Class Two” mitigation 

measures that may have the potential to achieve increased emission reductions when 

compared to the required “Class One” mitigation measures. The Class Two mitigation 

measures are practices that are far beyond the requirements of Best Available Retrofit 

Control Technology (BARCT). These measures were included in the rule to give credit 

to operators who have made substantial investments in facilities and equipment that 

result in air quality benefits equivalent to or greater than those achieved by one of the 

Class One mitigation measures and to encourage operators to go beyond the basic rule 

requirements and implement innovative practices to further reduce emissions. 

However, these measures cannot be reasonably mandated because of a variety of 

concerns including animal health, technological factors, environmental factors, and 

economic feasibility. The technological and economic feasibility of various selected 

Class Two mitigation measures are analyzed below to more clearly illustrate that it is 

not currently feasible to require facilities to implement the Class Two mitigation 

measures. 

II. VENTING SILAGE TO A CONTROL DEVICE 

The previous version of Rule 4570 contained the options to enclose silage in a bag or 

weatherproof structure and vent the silage to a VOC control device as Class Two 

Mitigation Measures. At the time Rule 4570 was being developed, preliminary 

information indicated that dairy feed was an important source of VOC emissions at 

dairies. More recent research has confirmed that feed at dairies is a significant VOC 

emissions source. The options to vent silage to a VOC control device were included as 

potential means to reduce emissions from this important source. The proposed controls 

were not based on any known installations but were based largely on technology 

transfer from composting operations, which were thought to involve a similar process. 

However, an examination of the processes required for composting and creating silage 

demonstrates that the fundamental differences in the processes cause actively venting 

silage to a control device to be infeasible, therefore these options have been removed 

from the revised rule. 

Composting is an aerobic process in which microbes decompose organic material in the 

presence of oxygen producing carbon dioxide and heat. The end product is a humuslike product that can be used to increase the organic matter and porosity of soil. 

Because composting is an aerobic process, any air that is vented through the material 

being composted can speed or enhance the composting process and result in a more 

consistent end-product. Therefore, actively venting composting piles is feasible and 

may even be desirable. Production of silage is fundamentally different because it is an 

anaerobic process. The purpose of silage production is to move the ensiled plant 
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material from an aerobic phase to an anaerobic phase as quickly as possible and 

achieve a rapid drop in pH that will hinder further microbial decomposition in order to 

preserve the nutritive value of the forage. The rapid drop in pH is primarily caused by 

conversion of soluble carbohydrates to nonvolatile lactic acid. Oxygen, heat, and the 

production of carbon dioxide, which are desirable when producing compost, are 

undesirable when producing silage because this is indicative of lost dry matter and 

energy content. Preservation of dry matter and energy content is the entire purpose of 

making silage because the nutrients and energy are used by cows to produce milk and 

maintain body weight. They are also used by the younger stock for growth. Aerobic 

deterioration and heating of silage in bunkers or piles and when fed to animals in the 

total mixed ration (TMR) are well-known problems. Many steps are taken to prevent 

this loss of nutritive value. Active venting of silage would introduce oxygen into the 

silage and result in the losses of nutritive value that producers are attempting to avoid. 

Therefore, this option is not feasible for production of silage. 

Passive venting of silage to a control device may be considered to be more feasible but 

this option is not currently reasonable. Because of the need to maintain anaerobic 

conditions to preserve the nutritive value of the silage, silage piles are usually tightly 

compacted and covered with plastic to prevent air penetration. Because most of the 

surface area of silage piles will usually have a compacted surface covered by plastic, 

the vast majority of emissions will be from the part of the pile that is uncovered to allow 

removal of feed. Machinery must access this open portion of the silage pile at various 

times throughout the day to obtain feed for the animals; therefore, enclosing this portion 

of the pile to allow passive ventilation is not reasonable. The District also considered 

including an option requiring that silage piles be re-covered after feed removal; 

however, this option also proved to be unreasonable because of safety concerns. The 

silage piles constructed in the San Joaquin Valley are extremely large. Producers will 

generally try to minimize the amount of work that is performed on or near open silage 

piles because of the danger of the silage pile collapsing, which can result in serious 

injury or death. The District consulted with experts in the field of silage production and 

they agreed that large silage piles are a safety concern and advised against including 

any measures that would require workers to spend time on or near open silage piles. 

These experts stated that silage piles are serious hazards and, unfortunately, injuries 

and/or deaths from silage pile avalanches probably occur every year1

. Because of these 

important safety concerns, the option to have workers re-cover piles was not considered 

further under the current rule revisions. 

1

 Recent incidents of silage piles collapsing on people can be found at the following links (unfortunately, 

additional similar incidents can easily be found by a simple web search): 

http://hayandforage.com/hay/0201-surviving-silage-avalanche/

http://www.thaindian.com/newsportal/world/boy-dies-due-to-feed-pile-collapse_100354252.html

http://www.agsafety.psu.edu/newsletters/MarApr07.pdf 
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III. MILK PARLORS VENTED TO A CONTROL DEVICE

Because the same control device could be used to control VOC emissions from the milk 

parlors and the cow housing, cost of the VOC emission reductions for an enclosed milk 

parlor was evaluated below in conjunction with the cost of VOC emissions from 

enclosed cow housing vented to a control device. Since the emission factor from the 

milking parlors is much lower than the emission factor from the cow housing, this 

reduces the cost of emission reductions for venting the milking parlors to a control 

device. The use of a biofilter as the control device for VOCs is expected to result in 

much lower costs than other control options, such as incineration; therefore, this option 

was analyzed below to determine the minimum cost of the emission reductions that 

could be achieved by venting an enclosed milk parlor and enclosed freestall barns 

vented to a control device. Details of this analysis are given under Section IV – 

Analysis for Confining Livestock in Enclosed Buildings and Venting Emissions to a 

Control Device. 

 

Description of a Milking Parlor

Milk parlors can be either naturally or mechanically ventilated. Mechanical ventilation 

can be easily applied to all areas of the milking parlors, except the holding area. The 

mechanical ventilation system for the milking parlor can be utilized to capture the gases 

emitted from the milking parlor; however in order to capture all of the gases, and to keep 

an appropriate negative pressure throughout the system, the holding area would also 

need to be entirely enclosed. No California facility that currently encloses the holding 

area could be identified because cows are continuously going in and out of the barn 

throughout the day. The capital cost required to enclose this large area would also be 

significant. Although the feasibility of such a technology is in question, it will be 

considered in the analysis below. If it is possible to overcome the significant obstacles 

to properly capturing the gases, it may be possible to vent them to a control device. 

 

Description of Control Technology

A biofilter is a device for removing contaminants from a gas in which the gas is passed 

through a media that supports microbial activity by which pollutants are degraded by 

biological oxidation. During biofiltration microorganisms oxidize the gaseous organic 

contaminants, ammonia, and sulfur compounds in the exhaust air resulting in carbon 

dioxide, nitrogen, water, salt, and biomass. Additional information on biofiltration is 

given below in the analysis for enclosed animal housing vented to a control device. 

Cost of VOC Emission Reductions

The analysis below for enclosed milk parlors and enclosed freestall barns vented to a 

biofilter demonstrates that the cost of the VOC reductions would be greater than 

$205,081/ton. There are additional costs related to increased electricity use, and 

regulatory compliance and testing that have not been quantified for this analysis. Even 
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without these costs, it is clear that the cost of the VOC emission reductions achieved 

are far beyond BARCT and any applicable RACT requirements. 

IV. ANALYSIS FOR CONFINING LIVESTOCK IN ENCLOSED BUILDINGS AND 

VENTING EMISSIONS TO A CONTROL DEVICE

It has been periodically suggested that large VOC emission reductions can be achieved 

by confining livestock in enclosed buildings and using mechanical ventilation to direct 

the emissions to a control device, such as an incinerator or biofilter. The District 

previously considered this option when the District originally adopted Rule 4570. The 

District determined that this option was beyond both Best Available Retrofit Control 

Technology (BARCT) and Best Available Control Technology (BACT) because it had 

not been achieved in practice at any facility and would have excessively high costs. 

Although the District considered this option to be a theoretical measure that was beyond 

BARCT and BACT, it was included in Rule 4570, like several other Class 2 measures, 

to encourage the development of innovation technologies that might possibly lead to 

greater emission reductions in the future. 

In the BACT evaluations for several projects for new or modifying dairies, the District 

analyzed the cost of the VOC emission reductions from venting dairy barns to a control 

device. Although these abbreviated cost analyses only considered a small fraction of 

the total costs associated with this measure, they consistently resulted in costs of 

emission reductions that exceeded the District’s cost effectiveness threshold for BACT 

for VOC. The District has repeatedly demonstrated that this measure is beyond BARCT 

and BACT, and certainly beyond the less stringent requirements of Reasonably 

Available Control Technology (RACT). However, certain parties continue to suggest 

that, not just new or expanding dairies, but all existing dairies subject to Rule 4570 

should be required to confine their herd in enclosed buildings vented to a control device. 

This analysis does not quantify all of the costs or examine all of the potential issues that 

make requiring this option infeasible but it is intended to be a more complete analysis 

that more accurately approaches the actual costs to implement this measure. The use 

of a biofilter as a control device for VOCs is expected to result in much lower costs than 

other control options, such as incineration. The U.S. Environmental Protection Agency 

(US EPA), Clean Air Technology Center (CATC) document “Using Bioreactors to 

Control Air Pollution” states, “The capital cost of a bioreaction installation is usually just 

a fraction of the cost of a traditional control device installation. Operating costs are 

usually considerably less than the costs of traditional technology, too.”2

 Therefore, this 

analysis will evaluate the use of a biofilter to determine the minimum cost of the 

emission reductions that would be achieved by venting enclosed animal housing to a 

control device. 

2

 U.S. Environmental Protection Agency , The Clean Air Technology Center (CATC), “Using Bioreactors 

to Control Air Pollution” EPA-456/R-03-003, (E143-03), September 2003, 

http://www.epa.gov/ttn/catc/dir1/fbiorect.pdf
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A. Biofilter Information 

Description of Control Technology

A biofilter is a device for removing contaminants from a gas in which the gas is passed 

through a media that supports microbial activity by which pollutants are degraded by 

biological oxidation. During biofiltration, exhaust air containing pollutants passes 

through a media that contains an established, diverse population of aerobic 

microorganisms. These microorganisms oxidize the gaseous organic contaminants, 

ammonia, and sulfur compounds in the exhaust air resulting in carbon dioxide, nitrogen, 

water, salt, and biomass. The bacterial cultures (microorganisms that typically consist 

of several species coexisting in a colony) that use oxygen to biodegrade organics are 

called aerobic cultures. These aerobic cultures are usually supported by organic 

material contained in the biofilter, such as compost, wood chips, soil, peat, etc. 

Biofilters must maintain sufficient porosity to allow the contaminated air stream to pass 

through for treatment and to prevent anaerobic conditions. The moisture content of 

biofilter beds must also be regulated to ensure that there is sufficient moisture to 

maintain the microorganisms needed for treatment while avoiding excess moisture that 

can cause anaerobic conditions. A filtration system may be required upstream of the 

biofilter to remove particular matter which will clog the biofilter over time. Biofilters must 

be maintained free of rodents and weeds to avoid channeling of gases through the filter 

media and a loss of performance. The filter media of natural biofilters needs to be 

replaced periodically because of deterioration and loss of porosity. 

Since biofilters rely on living organisms to function, a biofilter’s performance will be 

affected by several factors, including: ambient temperature; temperature of the air 

stream being treated; the pollutant concentrations in the air stream; moisture content of 

the filter and air stream, and pH of the filter media. These parameters should be 

monitored to ensure optimum operating conditions for the biofilter. 

Advantages and Disadvantages of Using a Biofilter to Control Emissions 

Some of the general advantages related to the use of biofilters include: low installation 

costs for traditional biofilter designs; generally low operating costs in comparison to 

other control technologies; high control efficiencies for some compounds such as 

aldehydes, organic acids, hydrogen sulfide, and certain water-soluble organic 

compounds. 

Some of the general disadvantages of the use of biofilters include: large land 

requirements for traditional biofilter designs; difficulty in determining the control 

efficiency for traditional open biofilter designs; for biofilters that use inexpensive natural 

bed media, the filter bed media must be replaced every 2 to 5 years; biofilters usually 

require some time to reach optimum control efficiency after initial startup and after 

periods of nonuse because of the need to establish or re-establish the microbial 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

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Revised Proposed Amendments to Rule 4570 

population; and biofilters can also be a source of nitrous oxide emissions due to 

denitrification. 

Additional disadvantages specifically related to the use of biofilters to control emissions 

from livestock include: animals that may currently have access to corrals or pasture for 

exercise would need to be confined in buildings to maximize emission reductions; 

facilities that currently use natural ventilation would incur additional costs because of the 

need to convert to mechanical ventilation; facilities that currently use mechanical 

ventilation systems may need to upgrade these systems to overcome the increased 

pressure drop across the biofiltration system; greater energy usage for all facilities to 

push air through the biofilter; few reported cases where a biofilter has been shown to be 

economically viable when applied to animal feeding operations3

; a very large biofilter 

system must be used to handle these huge flow rates while maintaining adequate 

contact time for treatment of emissions. Finally, because of the extremely large airflow 

rates needed to provide adequate ventilation for livestock it is not practical and may not 

be feasible to treat all of the ventilation air from large confined animal housing units. 

Biofilter VOC Control Efficiency

It is assumed that 80% of the gasses emitted from the enclosed animal housing will be 

captured by the mechanical ventilation system and that a properly functioning biofilter 

will eliminate 85% of the captured VOC emissions4; therefore, the total control for VOCs 

from the enclosed animal housing = 0.80 x 0.85 = 68%. 

Cost Estimates for Biofilters

Several reference documents were consulted to determine the expected capital and 

operating costs of using a biofilter to control VOC emissions from enclosed animal 

housing. These references and the resulting cost information are listed below. 

Additionally, several companies that specialize in building and supplying biofilters and 

bio-scrubbers for the control of VOC emissions were contacted to request capital cost 

estimates for biofilter systems specifically for the treatment of VOC emissions from dairy 

cows housed in enclosed barns. The dollar amounts of the estimates provided by these 

companies are also listed below. 

Sources of Cost Estimates for Biofilters

Table 1 summarizes the cost information for biofilters found in literature. The 

references follow the table. 

 

3

 U.S. Environmental Protection Agency, “Emissions from Animal Feeding Operations” (Draft), EPA 

Contract No. 68-D6-0011, August 15, 2001, pg. 9-20, 

http://www.epa.gov/ttn/chief/ap42/ch09/draft/draftanimalfeed.pdf 4

 The SCAQMD Rule 1133.2 staff report (page 18) indicates control efficiencies of 80-90% for VOC for 

existing biofilter composting applications and that a well-designed, well-operated, and well-maintained 

biofilter is capable of achieving 80 percent control efficiency for VOC, 

http://www.aqmd.gov/rules/doc/r1133/r1133_staffreport.pdf 
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Revised Proposed Amendments to Rule 4570 

Table 1 – Biofilter Costs from Literature 

Article 

Number 

Year 

published 

Capital Cost 

Range ($/cfm) 

Adj 2010 

Capital Cost 

($/cfm) 

Operating Cost 

Range 

($/cfm/yr) 

Adj 2010 

Operating Cost 

($/yr) 

1 2003 $2.35 - $7.74 

biofilter $6.67 $3.31 biofilter $4.07 

2 2003 $20.20 - 30.30 

biotrickling filter $33.34 $6.35 biotrickling filter $7.81 

3 1991 $12.79 - $20.93 

open biofilter 

$22.43 - 

$36.70 

4 1991 $20.93 - $116.28 

enclosed biofilter 

$36.70 - 

$203.90 

5 1998 - - $2 - $14 $2.85 - $19.96 

6 2008 $15 $15.91 $2 $2.12 

7 2005 $16.99 - $118.93 $19.70 - 

$137.87 $5.10 - $16.99 $5.91 - $19.70 

8 1996 $2.50 - $5.00 $3.07 - $6.15 $'2 - $14 $2.46 - $17.22 

9 1999 $13.30 - $18 $18.401 - 

$24.92 $3.33 - $6.67 $4.61 - $9.23 

10 2002 $2.79 $3.53 10% of capital cost 

11 2004 $0.15 - $0.25 $0.25 - $0.35 $0.005 -$ 0.015 $0.006 - $0.018 

1 & 2. U.S. Environmental Protection Agency, The Clean Air Technology Center 

(CATC), “Using Bioreactors to Control Air Pollution” EPA-456/R-03-003, (E143-03), 

September 2003, http://www.epa.gov/ttn/catc/dir1/fbiorect.pdf

3. U.S. Environmental Protection Agency, “Emissions from Animal Feeding Operations” 

(Draft), EPA Contract No. 68-D6-0011, August 15, 2001, Section 9.2.3 - Biofiltration of 

Confinement Housing Exhaust, 

http://www.epa.gov/ttn/chief/ap42/ch09/draft/draftanimalfeed.pdf

4. Leson, G. and A.M. Winer. 1991. “Biofiltration: An Innovative Air Pollution Control 

Technology for VOC Emissions”. Journal of the Air and Waste Management 

Association. 41(8):1045-54.) 

5. Operating Cost Estimate for a Biofilter (1998): $2-14/cfm (from Boyette, R. A. 1998. 

“Getting Down to (Biofilter) Basics”. Biocycle 39(5):58-62) 

6. Bohn, Hinrich, “Biofilter Technology Offers Emissions Abatement Option”, Distillers 

Grain Quarterly, 3rd Qtr 2008, http://www.ethanolproducer.com/dgq/articleprint.jsp?article_id=1257
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Revised Proposed Amendments to Rule 4570 

7. Delhoménie, Marie-Caroline; Heitz, Michèle, “Biofiltration of Air: A Review”, Critical 

Reviews in Biotechnology, 1549-7801, Volume 25, Issue 1, 2005, Pages 53 – 72 

8. Boyette, R. Allen – E&A Environmental Consultants Inc., “Biofilter Economics and 

Performance”, 1996, http://www.p2pays.org/ref/12/11505.pdf

9. Govind, Rakesh – PRD Tech Inc., White Paper - “Biofilteration: An Innovative 

Technology for the Future”, 1999, 

http://www.prdtechinc.com/PDF/PRDBIOFILTERR&DMAGAZINEPAPER.pdf

10. South Coast Air Quality Management District, “Technology Assessment for: 

Proposed Rule 1133: Emission Reductions from Composting and Related Operations”, 

March 22, 2002, http://www.aqmd.gov/rules/doc/r1133/r1133_techassessment.pdf

11. Schmidt, David. Janni, Kevin. Nicolai, Richard. “Biofilter Design Information”. 

Biosystems and Agricultural Engineering Update: BAEU-18, Revised March 2004. 

University of Minnesota Department of Biosystems and Agricultural Engineering, 

College of Agricultural, Food and Environmental Sciences, 

http://www.manure.umn.edu/assets/baeu18.pdf

Note: The capital cost estimate obtained from this source was ten times lower than 

the low-end of the cost estimates given in other sources listed above and the 

estimates from biofilter suppliers presented below and the operating cost estimate 

from this source was more than 100 times lower than the lowest the cost estimates 

given in the other sources listed above. Because of this significant difference in 

costs, the design of this biofilter was evaluated to determine if it would meet District 

and EPA standards for an add-on VOC control device. This preliminary evaluation is 

discussed below. 

Reference #11 describes a biofilter designed to reduce odors not total VOCs. The 

document recommends that an open-bed biofilter used to control exhaust from animal 

housing have a depth of 10-18 inches and an empty bed contact time of 3-5 seconds. 

For an open-bed biofilter used for VOC control, the recommended depth and contact 

time are generally 3-5 feet and 30-60 seconds, respectively. The lower recommended 

depth is the result of limitations with typical exhaust fans used for ventilation in animal 

housing, which are not designed for the larger pressure drops that would be caused by 

a deeper biofilter bed. It is likely that the much smaller recommended contact time is 

related to the fact that the biofilter is only designed to reduce odors. Many odorous 

compounds are branched-chain volatile fatty acids (VFAs) that consist of large 

molecules with a strong tendency to adhere to any surfaces that they contact; thus 

shortening the contact time required to treat these compounds. Although VFAs are 

largely responsible for objectionable odors from agricultural facilities, recent studies 

have shown that alcohols comprise the majority of VOC emissions. The biofilter design 

recommended in the document would not be as effective for reducing alcohols or other 

VOCs which are more volatile and do not have a strong tendency to adhere to surfaces. 
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Revised Proposed Amendments to Rule 4570 

The biofilter does not appear to be designed to handle the total flow rates from the 

animal housing but is probably intended to handle smaller flow rates from high-odor 

areas such as manure pits. Another limitation with the design is that there is no 

dedicated outlet to allow measurement and determination of control efficiency; thus 

there isn’t any way to accurately assess if the biofilter is functioning properly. Because 

of the substantial deviation from established criteria for the design of biofilters for control 

of VOCs and the lack of information to support and quantify total VOC reductions from 

this particular design, the cost estimates associated with this design will be removed 

from further consideration. This design may be re-evaluated at a later time if the 

necessary information is provided or becomes available. 

Quotes/Estimates Received from Providers of Biofilters/Bio-Scrubbers for VOC Control

As stated above, several companies that supply biofilters and bio-scrubbers for the 

control of VOC emissions were contacted to request capital cost estimates for biofilter 

systems capable of treating VOC emissions from dairy cows confined in enclosed 

barns. The companies that were contacted include: 1) Tri-Mer Corporation; 2) 

BioReaction Industries; 3) PRD Tech, inc.; 4) Siemens Water Technologies; 5) PPC Air 

Pollution Control Systems - PPC Biofilter; 6) Biorem/TEC Treatment Equipment 

Company; and 7) MEGTEC Systems, Inc. 

Four vendors responded to the District’s request for cost information. They are 

identified as Vendors A, B, C, and D in Table 2. The companies were provided 

information regarding the type of VOCs that would be treated (mostly alcohols and 

VFAs) and were told that the biofilter would need to be capable of treating airflow rates 

of 500,000 cfm or more. The estimates that were provided by these companies are 

listed below and generally fell in the range of values given in the accepted sources 

listed above. 

Table 2 – Summary of Vendor Cost Information 

Vendor Capital Cost ($) Operating Cost ($/cfm) 

A $1.4 - $2.2 million $2.8 - $4.4 

B $8 - $10 million $16 - $18 

C $7 million ± 20% $14 ± 20% 

D - $20 - $25 

Reduced Capital Cost from Economy of Scale

The potential for reduced dollar-per-cfm capital costs was considered based on the 

large airflow rates that would be handled by biofilters for confined animal facilities. 

Based on the information reviewed, it was determined that there is not any additional 

cost reduction benefit related to economy of scale for biofilters handling such large flow 

rates. 

 
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Revised Proposed Amendments to Rule 4570 

The information available indicates significant reductions in biofilter costs per cfm as the 

flow rate treated increases to a few thousand cfm but diminishing reductions in cost 

after this until there is no further benefit. This is illustrated in the graph below. The 

graph shows no additional cost reductions benefits after approximately 50,000 cfm. 

Also, in a phone conversation with Jim Cash of MEGTEC Systems, Inc. he stated that 

economy of scale cost reductions for biofilter systems were insignificant after 

approximately 20,000 cfm. This was because multiple individual units are generally 

required to treat flows greater than this and each unit would still cost about the same. 

Additionally, single units, and sometimes even multiple units, handling such large flow 

rates would not be pre-fabricated but would have to be specially constructed on site, 

which can increase costs. This was also supported by the information provided by other 

biofilter suppliers. Therefore, any potential cost reduction benefits related to economy 

of scale have already been captured in the lower biofilter cost estimates given above 

and no additional cost benefits will be realized at higher flow rates. As a result, the cost 

estimates for biofilters will be directly proportional to the airflow rate treated and the 

number of animals housed. 

Boyette, R. Allen – E&A Environmental Consultants Inc., “Biofilter Economics and Performance”, 1996

Cost Estimate for Biofilters for this Analysis

For purposes of this report, the following biofilter cost estimates will be used. The cost 

estimates are conservative and are significantly lower than some of capitol cost 

estimates given in the references listed above. 
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Revised Proposed Amendments to Rule 4570 

Capital Cost (2010): $3-35/cfm

Operating Costs (2010): $2.12-20/cfm

B. Analysis of Enclosed Dairy Barns Vented to a Control Device 

The following analysis is based on the cost of emission reductions for confining 1,000 

milk cows in enclosed freestall buildings vented to a biofilter and venting the milking 

parlor to the same biofilter. Costs for larger dairies would be linearly proportional.

Description of Dairy Housing

In a freestall barn, cows are grouped in large pens with free access to feed bunks, 

water, and stalls for resting. In the mild climate of the San Joaquin Valley, the typical 

freestall barn is an open structure (roof but no sides). The primary freestall design 

consists of a roof that provides shade with all sides open to allow air to flow through, 

which keeps the cows cool. The open freestall barns take advantage of natural summer 

winds in the San Joaquin Valley that are generally greater than four mph. The natural 

winds result in an excellent summer ventilation rate that is equivalent to 1,000 cfm per 

cow more, which is why open dairy barns are generally recommended in the San 

Joaquin Valley. In colder climates enclosed or partially enclosed barns may be utilized 

to protect cows from winter extremes. However, no completely enclosed freestall barns 

that were installed at a California dairy were identified. 

Although the potential to enclose cows in a barn may exist, the feasibility of reasonably 

collecting the gas through a stack, chimney, or vent remains in question considering the 

extremely large amounts of airflow going through the barns needed to keep the cows 

cool. The airflow requirements would be even higher in the San Joaquin valley, where 

temperatures can exceed 110° F in the hot summer. If the barn exhaust can be properly 

captured it may be possible to vent it to a biofilter for VOC control. Some of the 

potential disadvantages related to the use of a biofilter to control emissions from 

enclosed livestock barns were mentioned above. One of the disadvantages mentioned 

was the large space requirement for the traditional biofilter design. To further illustrate 

this, a low-cost natural bed biofilter designed to treat the VOC emissions from 1,000 

milk cows and 180 dry cows with no support stock would cover more than 5.4 acres and 

would need to be maintained free of pests and approved by the appropriate permitting 

agencies. To avoid such expansive land requirements, the dairy would likely need to 

use much more expensive bio-trickling filters or bio-scrubbers. 

Even though questions remain about the reasonability of requiring animals to be 

confined in buildings and venting the exhaust to a biofilter, it will be considered for 

purposes of this analysis. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-14 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Source of Cost Estimates for Enclosed Freestall Barns

Table 3 – Cost Estimates for Enclosed Freestall Barns 

Article 

Number 

Year 

published 

Capital Cost 

Range ($/cow) 

Adj 2010 Capital 

Cost ($/cow) 

Operating 

Cost Range 

($/cow/yr) 

Adj 2010 

Operating 

Cost 

($/cow/yr) 

1 2002 $1,430 - $1.750 $1,812 - $2,217 

2 2006 $1,500 $1,688 

3 2009 +$500 than 

conventional $1,851 - $2,717 

4 2010 $2,000 - $2,700 $2,000 - $2,700 

5 2008 - - 

+$127/cow 

more than 

conventional 

+$135/cow

6 2008 - - $69.95 - 

$92.23 

$74.21 - 

$97.85 

1. Jones, Lawrence R., “Choosing a Freestall Barn Style”, June 18, 2002, 

http://www.milkproduction.com/Library/Articles/Choosing_a_Freestall_Barn_Style.htm

2. Quaife, Thomas, “Tunnel Ventilation: So far, so good”, Dairy Herd Management, 

February 2006, http://www.dairyherd.com/directories.asp?pgID=724&ed_id=5169

3. DiGuiseppe, Gary, “Cow Comfort Innovations in the barn”, American Dairymen, Vol. 

35, Number 3, March 2009, http://www.americandairymen.com/articles/cow-comfortinnovations-barn

4. Emails from Paul Martin of Western United Dairymen based on contacts in New 

York 

5. Gooch, Curt, “Dairy Freestall Barn Design – A Northeast Perspective”, Presented at 

the Ninth Annual Fall Dairy Conference - Cornell University College of Veterinary 

Medicine and Cornell PRO-DAIRY Program. November 12 -13, 2008, 

http://www.ansci.cornell.edu/pdfs/pddairybarndesign.pdf

6. Dhuyvetter, Kevin C., Harner, Joe P., Smith, John F., & Bradford, Barry J., Kansas 

State University Department of Agricultural Economics, “Economic Considerations of 

Low-Profile Cross-Ventilated Freestall Barns”, Presented at Dairy Housing of the 

Future, Sioux Falls, South Dakota. September 10-11, 2008, 

http://www.agmanager.info/dhuyvetter/presentations/2008/LPCV%20Conference(Sep20

08).pdf
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-15 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Cost Estimates for Enclosed Freestall Barns for this Analysis

Based on the information above, the following cost estimates will be used for this 

analysis. 

Capital Cost (2010): $1,700-2,700/cow 

Estimated Adjusted Capital Cost: $1,275-2,025/cow (capital cost estimate reduced by 

25% because it may be possible to use the existing concrete work and some of the 

existing freestall infrastructure with the new building shell) 

Increased Operating Costs: $74-135/cow more

Capital Cost for Freestall Barn Enclosure for 1,000 milk cows

Low capital cost estimate: $1,275/cow x 1,000 cows = $1,275,000 

High capital cost estimate: $2,025/cow x 1,000 cows = $2,025,000 

Increased Operating Costs for Enclosed Freestall Barn for 1,000 milk cows

Low operating cost estimate: $74/cow-yr x 1,000 cows = $74,000/yr 

High operating cost estimate: $135/cow-yr x 1,000 cows = $135,000/yr 

Cost of Biofiltration

The cost estimates for biofiltration are based on the references given above. The cost is 

largely dependent on the airflow rate that the biofilter must handle. Biofilters used to 

treat exhaust air should be sized to treat the maximum ventilation rate, which is typically 

the warm weather rate. The higher cost value is representative of a biotrickling filter, 

which may be necessary to handle the high air flow rates from the barns. 

Capital Cost for a biofilter: $3-35/cfm 

Operating Costs for a biofilter: $2.12-20.00/cfm-yr 

Required Airflow Rate of the Freestall Barns

In order to calculate the costs of this control option, the airflow rate required for the 

freestall barns must be determined. The University of Minnesota’s publication 

“Improving Mechanical Ventilation in Dairy Barns”, gives minimum ventilation rates for 

dairy cattle, which are listed in the table below. 

Table 4 - Minimum Ventilation Rates for Dairy Cows (cfm/cow) 

Age Winter Mild Weather Summer 

Baby Calf 15 50 100 

Heifer 

(2-12 months) 20 60 130 

Heifer 

(12-24 months) 30 80 180 

Mature Cow 50 170 500 – 1,000 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-16 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

The minimum summer ventilation rate listed for mature cows is 500 cfm per cow. 

However, according to the University of Minnesota publication and Cornell University’s 

publication “Natural or Tunnel Ventilation of Freestall Structures: What is Right for Your 

Dairy Facility?”, the required airflow rate in the summer increases to 1,000 cfm per cow 

if tunnel ventilation is used to provide additional cooling.5

 

The climate in the San Joaquin Valley is characterized by mild winters and hot 

summers. Because of the warmer climate, it is expected that tunnel ventilation or a 

similar system would need to be employed in an enclosed freestall barn to prevent 

excessive heat stress. Additionally, tunnel ventilation systems are more representative 

of the types of systems that would be required to capture and control emissions. 

Minimum Summer Air Requirements for freestall barns vented to a biofilter for 1,000

milk cows:

The minimum required summer airflow rate for housing the 1,000 milk cows in enclosed 

freestalls is calculated as follows: 

Low Summer Ventilation Rate: 1,000 milk cows x 500 cfm/cow = 500,000 cfm 

High Summer Ventilation Rate: 1,000 milk cows x 1,000 cfm/cow = 1,000,000 cfm 

Capital Cost of a Biofilter for 1,000 milk cows

The lower cost estimate does not include installation of the required ductwork. As stated 

above, the estimated capital costs for a biofilter range of between $3.00 per cfm and 

$35.00 per cfm. The capital cost estimates of a biofilter for enclosed freestall barns 

housing 1,000 milk cows are calculated as follows: 

Low capital cost estimate: $3.00/cfm x 500,000 cfm = $1,500,000 

High capital cost estimate: $35.00/cfm x 1,000,000 cfm = $35,000,000 

Operating Costs for a Biofilter for 1,000 milk cows

Low operating cost estimate: $2.12/cfm-yr x 500,000 cfm = $1,060,000/yr 

High operating cost estimate: $20.00/cfm-yr x 1,000,000 cfm = $20,000,000/yr 

Annualized Capital Costs for Biofilter for 1,000 milk cows

The annualized capital cost estimates will be calculated below. The cost for the 

purchase of the enclosed freestall barn and biofilter will be spread over the expected life 

of the system using the capital recovery equation. Therefore, the expected life of the 

entire system (enclosed barn, fans, media, plenum, etc) will be estimated at 10 years. 

A 10% interest rate is assumed in the equation and the assumption will be made that 

the equipment has no salvage value at the end of the ten-year cycle. 

 

5

 Improving Mechanical Ventilation in Dairy Barns, J.P. Chastain, 

http://www.milkproduction.com/Library/Articles/Improving_mechanical_ventilation.htm and Natural or 

Tunnel Ventilation of Freestall Structures: What is Right for Your Dairy Facility?, C.A. Gooch, 

http://www.ansci.cornell.edu/pdfs/nattunnel.pdf 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-17 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

A = [P x I(I+1)n]/[(I+1)n-1] 

Where: 

A=Annual Cost 

P=Present Value (freestall enclosure and biofilter) 

I=Interest Rate (10%) 

N=Equipment Life (10 years) 

Low Annualized Capital Cost Estimate = 

[($1,275,000 + $1,500,000) x 0.1(1.1)10]/[(1.1)10-1] = $451,618/year 

High Annualized Capital Cost Estimate = 

[($2,025,000 + $35,000,000) x 0.1(1.1)10]/[(1.1)10-1] = $6,025,648/year 

Total Annual Cost Estimates

The total annualized capital costs and operating costs for a freestall enclosure vented to 

a biofilter are given below. For the least expensive biofilters, the biofilter media (e.g., 

soil, compost, wood chips) must be replaced after 3-5 years in order to remain effective. 

This may be an additional cost because it is unclear if this cost was included in the least 

expensive operating cost estimates provided above. 

Total annual cost estimate = (total annualized capital cost) + (increased operating 

cost for an enclosed freestall barn) + (biofilter operating cost) 

Low total annual cost estimate = ($451,618/yr) + ($74,000/yr) + ($1,060,000/yr) 

= $1,585,618/year 

High total annual cost estimate = ($6,025,648/yr) + ($135,000/yr) + ($20,000,000/yr) 

= $26,160,648/year 

Potential Income from Increased Milk Production

Cooling milk cows in enclosed freestall barns may reduce heat stress and result in 

increased milk production. Because dairy cows in California already have some of the 

highest milk production rates in the nation, it is questionable regarding whether 

enclosing the milk cows will result in any significant increases in milk production. This is 

because heat stress is related to both temperature and humidity and it is likely that the 

increased temperatures in California relative to other states are mitigated by the much 

lower humidity. Although questions remain about the potential to increase milk 

production in the San Joaquin Valley by reducing heat stress, this potential benefit will 

be quantified for this analysis. 

Potential Increased Daily Milk Production: 4-6 lb/cow-day (District 4570 Staff Report, 

June 2006) 

Potential Increased Annual Milk Production: 1,460-2,190 lb/cow-yr 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-18 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Class 4b Price of milk6 for August 2010: $14.39/cwt 

Income from increased milk production: $210.09-315.14/cow-yr 

Max Income from increased milk production for 1,000 milk cows: 

1,000 milk cows x $315.14/cow-yr = $315,140/yr 

Low total annual cost estimate – income from increased milk production = 

($1,585,618/yr) - ($315,140/yr) = $1,270,478/year 

VOC Emission Reductions for Biofiltration for 1,000 Milk Cows

The annual VOC Emission Reductions for enclosed freestall barns for 1,000 milk cows 

vented to a biofilter are calculated as follows: 

[Number of cows] x [Cow Housing VOC EF (lb/cow-year)] x [Capture Efficiency] x 

[Biofilter Control Efficiency] 

Table 5 - VOC Reductions from Milk Cows Housed in Enclosed Freestall Barns 

Vented to a Biofilter (Cows, Stalls, & Lanes) 

Emissions Source # of 

cows 

x 

EF 

(lb/cow-yr) x Capture (%) x 

Control 

(%) = lb-VOC/yr 

Milk Cow (enteric)* 1,000 x 4.1 x 80% x 85% = 2,788 

Stalls and Lanes 1,000 x 1.8 x 80% x 85% = 1,224 

Milking Parlor Floor 1,000 x 0.03 x 80% x 85% = 20 

Total (lb-VOC/yr) 4,032 

*Includes emissions in the milk parlor(s) 

Table 6 - VOC Reductions from TMR (Feed) for Milk Cows Housed in 

Enclosed Freestall Barns Vented to a Biofilter 

# of 

cows 

EF 

(ug/m2

-min) 

Feed area 

per cow 

(m2) 

min/yr lb/ug = 

Uncontrolled 

lb-VOC/yr 

x Capture 

(%) x 

Control 

(%) = lb-VOC/yr

1,000 16,119 0.658 525,600 2.20462E-09 = 12,290 x 80% x 85% = 8,357 

Total VOC Emission Reductions from Milk Parlor, Cows, Stalls, Lanes, and Feed 

=4,032 lb-VOC/yr + 8,357 lb-VOC/yr = 12,389 lb-VOC/yr 

Cost of VOC Emission Reductions

Low Estimate7 =($1,270,478/year)/[(12,389 lb-VOC/year)(1 ton/2000 lb)] 

 = $205,098/ton of VOC reduced

 

6 http://www.cdfa.ca.gov/dairy/pdf/Prices_Grid.pdf; The Class 4b milk price was because dairy industry 

representatives state that increased production is purchased at the lowest price. Additionally, sufficient 

increased production will cause the price to fall 7

 Includes reduction in overall annual costs because of potential additional revenue from maximum 

supposed increase in milk production. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-19 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

High Estimate =($26,160,648/year)/[(12,389 lb-VOC/year)(1 ton/2000 lb)] 

 = $4,223,206/ton of VOC reduced

As shown above, the costs for a freestall enclosure and biofilter would cause the cost of 

the VOC reductions to be greater than $205,098/ton. There are additional costs related 

to increased electricity use, and regulatory compliance and testing that have not been 

quantified in this analysis. Even without these costs, it is clear that the cost of the VOC 

emission reductions achieved are far beyond BARCT and any applicable RACT 

requirements. 

C. Mechanically Ventilated Swine Housing Vented to a Control Device 

The cost of the VOC emission reductions for venting a mechanically-ventilated swine 

house to a control device is analyzed below. As stated above, a biofilter is expected to 

be the least costly control device so it was chosen for purposes of this analysis. 

Description of Ventilation in Swine Housing

Swine are typically housed in confinement buildings that are either totally enclosed or 

partially enclosed structures with open sidewalls with curtains. In totally enclosed 

housing, mechanical ventilation is used throughout the year. Mechanical ventilation is 

typically provided by an induced draft or negative-pressure system. An induced draft 

system pulls fresh air into the house from one end and exhausts on the other. A 

negative-pressure system draws fresh air into the house from side vents and out 

through the exhaust fan. Partially enclosed swine housing uses natural ventilation the 

majority of the year. In these buildings the sidewall curtains are opened and closed to 

control the house ventilation rate. Partially enclosed swine housing may also use 

mechanical ventilation when the curtains are closed due to weather conditions. 

Ventilation in swine housing is used to remove excess moisture, ammonia, and 

hydrogen sulfide from swine housing and to remove excess heat during the summer 

season. It may be possible to vent the exhaust from mechanically ventilated swine 

houses to a control device; therefore, this option will be analyzed. 

Cost of Biofiltration

The cost estimates for biofiltration are based on the references given above. The cost is 

largely dependent on the airflow rate that the biofilter must handle. Biofilters used to 

treat exhaust air should be sized to treat the maximum ventilation rate, which is typically 

the warm weather rate. The higher cost value is representative of a biotrickling filter, 

which may be necessary to handle the high air flow rates from the houses. 

Capital Cost for a biofilter: $3-35/cfm 

Operating Costs for a biofilter: $2.12-20.00/cfm-yr 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-20 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Required Airflow Rate of the Swine Houses

In order to calculate the costs of this control option, the maximum airflow to be treated 

from the houses the swine housing building must be determined. 

The MidWest Plan Service publication “Mechanical Ventilating Systems for Livestock 

Housing” (MWPS-32), gives minimum ventilation rates for finishing swine, which are 

listed in the table below. 

Table 7 - Minimum Ventilation Rates for Finishing Swine (cfm/head) 

Animal Type Winter Mild Weather Summer 

Finishing Swine 10 35 120 

Minimum Summer Air Requirements for Swine Housing for 3,000 Finishing Head:

The minimum required summer airflow rate for housing the 3,000 head of swine in 

enclosed housing is calculated as follows: 

Summer Ventilation Rate: 3,000 head x 120 cfm/head = 360,000 cfm 

Capital Cost of Biofilter for Swine Housing with 3,000 Finishing Head

The lower cost estimate does not include installation of the required ductwork. As stated 

above, the estimated capital costs for a biofilter range of between $3.00 per cfm and 

$35.00 per cfm. The capital cost estimates of a biofilter for mechanically ventilated swine 

housing with 3,000 finishing head are calculated as follows: 

Low capital cost estimate: $3.00/cfm x 360,000 cfm = $1,080,000 

High capital cost estimate: $35.00/cfm x 360,000 cfm = $12,600,000 

Operating Costs for Biofilter for Swine Housing with 3,000 Finishing Head

Low operating cost estimate: $2.12/cfm-yr x 360,000 cfm = $763,200/yr 

High operating cost estimate: $20.00/cfm-yr x 360,000 cfm = $7,200,000/yr 

Annualized Capital Costs for Biofilter for Swine Housing with 3,000 Finishing Head

The annualized capital cost estimates will be calculated below. The cost for the 

purchase of the biofilter will be spread over the expected life of the system using the 

capital recovery equation. Therefore, the expected life of the entire system (fans, 

media, plenum, etc) will be estimated at 10 years. A 10% interest rate is assumed in 

the equation and the assumption will be made that the equipment has no salvage value 

at the end of the ten-year cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Low Annualized Capital Cost Estimate = 

[($1,080,000) x 0.1(1.1)10]/[(1.1)10-1] = $175,765/year 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-21 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

High Annualized Capital Cost Estimate = 

[($12,600,000) x 0.1(1.1)10]/[(1.1)10-1] = $2,050,592/year 

Total Annual Cost Estimates

The total annualized capital costs and operating costs for the biofilter are given below. 

For the least expensive biofilters, the biofilter media (e.g., soil, compost, wood chips) 

must be replaced after 3-5 years in order to remain effective and this may be an 

additional cost. There would also be increased electricity usage to overcome the 

pressure drop caused by the biofilter. This cost was not quantified. 

Total annual cost estimate = (total annualized capital cost) + (biofilter operating cost) 

Low total annual cost estimate = ($175,765/yr) + ($763,200/yr) 

 = $938,965/year 

High total annual cost estimate = ($2,050,592/yr) + ($7,200,000/yr) 

 = $9,250,592/year 

VOC Emission Reductions for Biofilter for Swine Housing with 3,000 Finishing Head

The annual VOC Emission Reductions for mechanically-ventilated swine housing for 

3,000 finishing head vented to a biofilter are calculated as follows: 

[Number of Head] x [Poultry VOC EF (lb/head-year)] x [Capture Efficiency] x [Biofilter 

Control Efficiency] 

Table 8 - VOC Reductions from Enclosed Swine House Vented to a Biofilter 

Animal # of 

Head x 

EF* 

(lb/head-yr) x Capture (%) x

Control 

(%) = lb-VOC/yr 

Finishing Swine 3,000 x 4.2 x 80% x 85% = 8,568 

* Based on a study by Rumsey, 91% of swine facility VOC emissions are assumed to be from housing 

barns and 9% of VOC emissions are assumed to be from lagoons8

Cost of VOC Emission Reductions

Low Estimate = ($938,965/year)/[(8,568 lb-VOC/year)(1 ton/2000 lb)] 

 = $219,180/ton of VOC reduced

High Estimate = ($9,250,592/year)/[(8,568 lb-VOC/year)(1 ton/2000 lb)] 

 = $2,159,335/ton of VOC reduced

As shown above, the costs for a biofilter for swine housing would cause the cost of the 

VOC reductions to be greater than $219,180/ton. There are additional costs related to 

 

8

 Rumsey, I. C., “Characterizing Reduced Sulfur Compounds and Non-Methane Volatile Organic 

Compounds Emissions from a Swine Concentrated Animal Feeding Operation” (2010) – PhD dissertation 

submitted to the Graduate Faculty of North Carolina State University 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-22 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

increased electricity use, and regulatory compliance and testing that have not been 

quantified in this analysis. Even without these costs, it is clear that the cost of the VOC 

emission reductions achieved are far beyond BARCT and any applicable RACT 

requirements. 

D. Mechanically Ventilated Poultry Houses Vented to a Control Device 

The cost of the VOC emission reductions for venting a mechanically-ventilated poultry 

house to a control device is analyzed below. As stated above, a biofilter is expected to 

be the least costly control device so it was chosen for purposes of this analysis. 

Ventilation in a Poultry House

In poultry houses, ventilation is used to remove moisture and ammonia from the houses 

during the winter season and to remove excess heat and ammonia from the houses 

during the summer season. Partially enclosed housing structures have open sidewalls 

with curtains that are opened and closed to control the house ventilation rate. In totally 

enclosed housing, mechanical ventilation is used. Mechanical ventilation is typically 

provided by an induced draft or negative-pressure system. An induced draft system 

pulls fresh air into the house from one end and exhausts on the other. A negativepressure system draws fresh air into the house from side vents and out through the 

exhaust fan. Totally enclosed mechanically ventilated housing is known as tunnel-type 

housing or environmental housing. It may be possible to vent the exhaust from 

mechanically ventilated poultry houses to a control device; therefore, this option will be 

analyzed. 

Cost of Biofiltration

The cost estimates for a biofiltration are based on the references given above. The cost is 

largely dependent on the airflow rate that the biofilter must handle. Biofilters used to 

treat exhaust air should be sized to treat the maximum ventilation rate, which is typically 

the warm weather rate. The higher cost value is representative of a biotrickling filter, 

which may be necessary to handle the high air flow rates from the houses. 

Capital Cost for a biofilter: $3-35/cfm 

Operating Costs for a biofilter: $2.12-20.00/cfm-yr 

Required Airflow Rate of the Poultry Houses

In order to calculate the costs of this control option, the maximum airflow to be treated 

from the houses house must be determined. 

The MidWest Plan Service publication “Mechanical Ventilating Systems for Livestock 

Housing” (MWPS-32), gives minimum ventilation rates for poultry, which are listed in the 

table below. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-23 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Table 9 - Minimum Ventilation Rates for Poultry (cfm/bird) 

Animal Type Winter Mild Weather Summer 

Broiler/Layer (5 lb) 0.5 2.5 5 

Turkey (40 lb) 3.2 14 32 

Capital Cost of Biofilter for a Poultry House with 32,000 Broilers or Layers or 5,000 

Turkeys

The lower cost estimate does not include installation of the required ductwork. As stated 

above, the estimated capital costs for a biofilter range of between $3.00 per cfm and 

$35.00 per cfm. The capital cost estimates of a biofilter for mechanically ventilated poultry 

houses for 32,000 broilers or layers or 5,000 turkeys are calculated as follows: 

Low capital cost estimate: $3.00/cfm x 160,000 cfm = $480,000 

High capital cost estimate: $35.00/cfm x 160,000 cfm = $5,600,000 

Operating Costs for a Biofilter for a Poultry House with 32,000 Broilers or Layers or 

5,000 Turkeys

Low operating cost estimate: $2.12/cfm-yr x 160,000 cfm = $339,200/yr 

High operating cost estimate: $20.00/cfm-yr x 160,000 cfm = $3,200,000/yr 

Annualized Capital Costs for Biofilter for 32,000 Broilers or Layers or 5,000 Turkeys

The annualized capital cost estimates will be calculated below. The cost for the 

purchase of the biofilter will be spread over the expected life of the system using the 

capital recovery equation. Therefore, the expected life of the entire system (fans, 

media, plenum, etc) will be estimated at 10 years. A 10% interest rate is assumed in 

the equation and the assumption will be made that the equipment has no salvage value 

at the end of the ten-year cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Low Annualized Capital Cost Estimate = 

[($480,000) x 0.1(1.1)10]/[(1.1)10-1] = $78,118/year 

High Annualized Capital Cost Estimate = 

[($5,600,000) x 0.1(1.1)10]/[(1.1)10-1] = $911,374/year 

Total Annual Cost Estimates

The total annualized capital costs and operating costs for the biofilter are given below. 

For the least expensive biofilters, the biofilter media (e.g., soil, compost, wood chips) 

must be replaced after 3-5 years in order to remain effective and this may be an 

additional cost. There would also be increased electricity usage to overcome the 

pressure drop caused by the biofilter. This cost was not quantified. 

Total annual cost estimate = (total annualized capital cost) + (biofilter operating cost) 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-24 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Low total annual cost estimate = ($78,118/yr) + ($339,200/yr) 

 = $417,318/year 

High total annual cost estimate = ($911,374/yr) + ($3,200,000/yr) 

 = $4,111,374/year 

VOC Emission Reductions for a Biofilter for 32,000 Broilers or Layers or 5,000 Turkeys

The annual VOC Emission Reductions for a mechanically-ventilated poultry house for 

32,000 broilers or layers or 5,000 turkeys vented to a biofilter are calculated as follows: 

[Number of Birds] x [Poultry VOC EF (lb/bird-year)] x [Capture Efficiency] x [Biofilter 

Control Efficiency] 

Table 10 - VOC Reductions from Enclosed Poultry Houses Vented to a Biofilter 

Poultry Type # of Birds x 

EF 

(lb/bird-yr) x Capture (%) x

Control 

(%) = lb-VOC/yr 

Broiler 32,000 x 0.025 x 80% x 85% = 544 

Layer 32,000 x 0.025 x 80% x 85% = 544 

Turkey 5,000 x 0.1 x 80% x 85% = 340 

Cost of VOC Emission Reductions

 Broilers/Layers

 Low Estimate = ($417,318/year)/[(544 lb-VOC/year)(1 ton/2000 lb)] 

 = $1,534,257/ton of VOC reduced

 High Estimate = ($4,111,374/year)/[(544 lb-VOC/year)(1 ton/2000 lb)] 

 = $15,115,346/ton of VOC reduced

 Turkeys

 Low Estimate =($417,318/year)/[(340 lb-VOC/year)(1 ton/2000 lb)] 

 = $2,454,812/ton of VOC reduced

 High Estimate =($4,111,374/year)/[(340 lb-VOC/year)(1 ton/2000 lb)] 

 = $24,184,553/ton of VOC reduced

As shown above, the costs for a biofilter for poultry houses would cause the cost of the 

VOC reductions to be greater than $1,534,257/ton for broilers and layers and greater 

than $2,454,812/ton for turkeys. There are additional costs related to increased 

electricity use, and regulatory compliance and testing that have not been quantified in 

this analysis. Even without these costs, it is clear that the cost of the VOC emission 

reductions achieved are far beyond BARCT and any applicable RACT requirements. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-25 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

V. MECHANICALLY VENTILATED POULTRY HOUSES 

The analysis evaluates replacing naturally ventilated animal housing with mechanically 

ventilated housing. The effectiveness of this measure is related to rapidly reducing the 

moisture in the manure and the associated microbial activity that produces emissions. 

Because of this, this measure is only applicable when animals are housed inside a 

building and the animals produce manure that does not contain excessive amounts of 

moisture; therefore this analysis will evaluate this option only for poultry facilities 

because other types of animals are generally housed outside (e.g. feedlot cattle) or 

produce manure that is handled as a liquid (e.g. swine). The cost of the VOC emission 

reductions for replacing a naturally ventilated poultry house with a mechanically 

ventilated poultry house is analyzed below. The analysis will look at the costs for both 

turkeys and broilers. Because both broilers and laying hens have the same VOC 

emissions on a per bird basis and the overall costs of mechanically-ventilated housing 

for broilers is expected to be much less than mechanically-ventilated housing for laying 

hens because of the need for additional equipment for collection of eggs, the lower cost 

associated with mechanically-ventilated housing for broilers will also provide the 

minimum cost of VOC reductions when applying this measure to laying hens. The 

following analysis is based on typical broiler and turkey operations in California and 

demonstrates that replacing naturally ventilated poultry houses with mechanically 

ventilated houses is not cost-effective for existing facilities. The analysis of the VOC 

reductions for broiler houses also shows that the VOC emission reductions would not be 

cost effective for layers because mechanically ventilated houses for laying hens would 

have higher costs. 

Process Description for Typical Broiler and Turkey Houses in the San Joaquin Valley

Broilers and turkeys are produced to meet specific requirements of the customer, which 

can be a retail grocery store, fast-food chain, or an institutional buyer. The production 

cycle of broilers and turkeys is divided into two phases: brooding and grow-out. The 

brooding phase begins when freshly hatched chicks from local hatcheries are delivered 

and placed in a heated section of a poultry house known as the brood chamber. The 

brood chamber of the house is kept warm for newly hatched chicks. In a typical poultry 

house in the San Joaquin Valley about 20,000 - 35,000 broiler chicks or 8,500 turkey 

poults are released into each house at the beginning of each grow-out period. During 

the birds’ first few weeks of growth, the temperature is gradually decreased. After 

completion of the grow-out phase the broilers and turkeys are transported to a nearby 

processing plant. The length of the grow-out phase for broiler chickens is approximately 

45 days, resulting in an average weight of 4.5 to 5.5 pounds. Turkey hens are usually 

grown for 14 to 16 weeks and turkey toms are usually grown for 17 to 21 weeks. 

As discussed above, ventilation in poultry houses is used to remove moisture and 

ammonia from the houses during the winter season and to remove excess heat and 

ammonia from the houses during the summer season. In totally enclosed housing, 

mechanical ventilation is provided by an induced draft or negative-pressure system. 
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Revised Proposed Amendments to Rule 4570 

Description of Control Technology

The mechanically ventilated environmental houses will have advanced environmental 

control system that uses thermostats, sensors, and timers to more effectively control 

their exhaust fans. Environmental conditions (e.g. temperature, humidity, ventilation, 

and lighting) within the houses are usually controlled by a computer system and 

monitored by staff. The conditions in the houses are controlled in a manner to optimize 

animal growth, maintain animal health, minimize feed spoilage and waste, and reduce 

moisture and undesirable microorganisms in the houses. This tight control of 

environmental conditions has a positive impact on overall air quality. It is conservatively 

assumed that mechanically-ventilated environmental housing will reduce VOC 

emissions from poultry houses by 15%. 

Capital Cost of a Mechanically Ventilated Poultry Houses

The cost estimate for a mechanically ventilated poultry house is based on information 

taken from the University of California Cooperative Extension Poultry Fact Sheet No. 20 

“Chicken Meat Production in California” 9

 (June 1995). This publication gives an initial 

capital cost estimate of $115,000 for a broiler house for a 40 ft x 500 ft (20,000 sq. ft.) 

mechanically ventilated broiler house for 22,200 birds. Because this estimate is 15 years 

old, this cost will be updated to 2010 dollars assuming a 3% annual inflation rate. The cost 

estimate in 2010 dollars is calculated as follows: 

2010 Capital Cost Estimate = $115,000 x 1.03 (2010-1995) = $179,166 

Although this cost will be used for purposes of this analysis, some producers have 

provided more recent information indicating that the cost for mechanically ventilated 

environmental poultry houses is significantly higher. 

Turkey operations use the same housing structures as broilers but have fewer birds per 

house. The University of California Cooperative Extension, California Poultry Workgroup 

publication “Animal Care Series: Turkey Care Practices” 10 (May 1998) states that 

“Approximately 10,000 hens or 7,000 toms are placed in the typical 50 by 500 foot 

barn.” This results in an average of 8,500 turkeys per 25,000 sq. ft. house. Therefore, 

it will be assumed that the 20,000 sq. ft. broiler house described above can house 6,800 

turkeys (8,500 birds x 20,000 sq. ft./25,000 sq. ft.). 

Annualized Capital Cost a Mechanically Ventilated Poultry House for 22,200 Broilers or 

6,800 Turkeys

The annualized capital cost estimates will be calculated below. The cost for the initial 

cost of the poultry house will be spread over the expected life of the system using the 

 

9

 “Chicken Meat Production in California” University of California Cooperative Extension Poultry Fact Sheet 

No. 20 Ernst, Ralph A. (June 1995) http://animalscience.ucdavis.edu/avian/pfs20.htm 10 “Animal Care Series: Turkey Care Practices” University of California Cooperative Extension California 

Poultry Workgroup (May 1998) http://www.vetmed.ucdavis.edu/vetext/INF-PO_TurkeyCarePrax.pdf 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-27 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

capital recovery equation. The expected life of the entire system will be estimated at 10 

years. A 10% interest rate is assumed in the equation and the assumption will be made 

that the equipment has no salvage value at the end of the ten-year cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Annualized Capital Cost Estimate = [$179,166 x 0.1(1.1)10]/[(1.1)10-1] = $29,158/year 

VOC Emission Reductions for a Mechanically Ventilated Poultry House for 22,200 

Broilers or 6,800 Turkeys

The annual VOC Emission Reductions for a mechanically-ventilated poultry house for 

22,200 broilers and 6,800 turkeys are calculated as follows: 

[Number of Birds] x [Poultry VOC EF (lb/bird-year)] x [Mechanical Ventilation Control 

Efficiency] 

Broilers

= (0.025 lb-VOC/bird-year) (22,200 bird/house) (0.15) = 83 lb-VOC/house-year 

Turkeys

= (0.1 lb-VOC/bird-year) (6,800 bird/house) (0.15) = 102 lb-VOC/house-year 

Cost of VOC Emission Reductions

 Broilers/Layers

 Cost Estimate = ($29,158/year)/[(83 lb-VOC/year)(1 ton/2000 lb)] 

 = $702,602/ton of VOC reduced

 Turkeys

 Cost Estimate =($29,158/year)/[(102 lb-VOC/year)(1 ton/2000 lb)] 

 = $571,725/ton of VOC reduced

As shown above, the capital cost alone for mechanically ventilated poultry housing 

would cause the cost of the VOC reductions to be greater than $700,072/ton for broilers 

and layers and greater than $571,725/ton for turkeys. This cost does not include the 

costs of demolition of the existing naturally ventilated poultry house. Even without these 

costs, it is clear that the cost of the VOC emission reductions achieved are far beyond 

BARCT and any applicable RACT requirements.

VI. ANALYSES FOR MANURE HANDLING SYSTEMS 

A. Poultry House with a Belt Manure Removal System 

The cost of the VOC emission reductions for converting an existing poultry house to a 

manure-belt poultry house is analyzed below. The use of manure-belt houses is only 

applicable to birds that are housed in cages and would not be applicable to birds that 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-28 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

are housed directly on litter, which is the case for most broilers and turkeys; therefore, 

this analysis will be based on layer operations. In addition, forced drying of poultry 

manure inside poultry houses and forced drying of poultry manure that is directly 

removed from the houses on a frequent basis will generally require use of some type of 

manure belt handling system. Therefore, this analysis also serves to establish the 

minimum cost of VOC reductions for using an in-house poultry manure drying system. 

Description of Housing in a Typical Laying Hen Operation

Laying hens maintained for table egg production are usually confined in cages. This 

allows automation of feed distribution and egg collection. Most confinement facilities for 

laying hens are mechanically ventilated to remove the moisture and carbon dioxide 

produced by respiration. Exhaust fans draw air into the building through slots located 

along the perimeter of the roof. There are several types of cage systems including full 

and modified stair-step systems. With modified stair-step cage systems, upper cages 

are partially offset with a baffle diverting manure from upper cages away from lower 

cages. There are also cage systems that stack cages without any offset to maximize 

the number of birds per unit floor area. In single story buildings, full or modified stair 

systems are located over shallow manure collection pits that may be cleaned either by 

scraping or flushing. With stacked cage systems, a belt system under the cages can be 

used to collect and remove manure

Description of Control Technology

Belt systems can be used to handle manure generated by poultry confined in cages. 

Manure in manure-belt poultry houses drops onto belts beneath cages and is frequently 

removed from the house, usually several times per week. This is in contrast to deep-pit 

houses in which manure can accumulate in houses for several months to a year. Using 

belts to handle manure facilitates drying of the manure that falls on the belts. A forcedair drying system can also be used to further reduce the moisture content of the 

manure. The manure removed from the houses by the belt system can be transported 

and stored in separate manure storage areas, applied directly to land, or composted. 

Manure-belt houses facilitate rapid drying of manure, which reduces the time available 

in which biological activity in the manure can produce emissions of air contaminants. A 

number of studies have shown that overall emissions of odorous compounds and 

ammonia from poultry houses using belt manure removal systems are much lower than 

poultry houses using in-house pit storage of manure. It is conservatively assumed that 

manure-belt housing will reduce VOC emissions from poultry houses by 10%. 

Cost of a Manure-Belt House

The cost estimate for manure-belt poultry housing is based on information taken from the 

report “Economics of Controlling Ammonia Emission from Commercial Layer Farms”11

 

11 van Horne P. L. M., Brake J., Williams, C. M., “Economics of Controlling Ammonia Emission from 

Commercial Layer Farms”, Journal of Applied Poultry Science 1998. 7:61-68 

http://japr.fass.org/cgi/reprint/7/1/61.pdf 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

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Revised Proposed Amendments to Rule 4570 

(1998). This publication gives an initial capital cost estimate of $1.75 per bird and an 

annual maintenance cost of 3% of the initial capitol cost for conversion of an existing 

poultry house to a manure-belt house. Because the capitol cost estimate is 12 years old, 

this cost will be updated to 2010 dollars assuming a 3% annual inflation rate. The cost 

estimate in 2010 dollars is calculated as follows: 

2010 Capital Cost Estimate = $1.75/bird x 1.03 (2010-1998) = $2.495/bird 

The capital cost and annual maintenance costs for converting an existing 20,000 bird 

house to a manure-belt house are given as follows: 

Capitol Cost = 20,000 birds x $2.495/bird = $49,900 

Annual Maintenance Costs = $49,900 x 0.03 = $1,497/year 

Annualized Capital Cost of a Manure-Belt House for 20,000 birds

The annualized capital cost estimates will be calculated below. The cost for the initial 

cost of converting to a manure-belt house will be spread over the expected life of the 

system using the capital recovery equation. The expected life of the entire system will 

be estimated at 10 years. A 10% interest rate is assumed in the equation and the 

assumption will be made that the equipment has no salvage value at the end of the tenyear cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Annualized Capital Cost Estimate = [$49,900 x 0.1(1.1)10]/[(1.1)10-1] = $8,121/year 

Total Annual Cost Estimate

The total annualized capital costs and operating costs for converting an existing poultry 

house for 20,000 birds to a manure-belt house are given below. 

Total annual cost estimate = (total annualized capital cost) + (increased operating 

cost) 

Total annual cost = ($8,121/yr) + ($1,497/yr) = $9,618/year 

VOC Emission Reductions for a Manure-Belt House for 20,000 birds

The annual VOC Emission Reductions for a manure-belt poultry house for 20,000 birds 

are calculated as follows: 

[Number of Birds] x [Layer VOC EF (lb/bird-year)] x [Manure-Belt Control Efficiency] 

= (20,000 bird/house) x (0.025 lb-VOC/bird-year) x (0.10) = 50 lb-VOC/house-year 

Cost of VOC Emission Reductions

Cost Estimate =($9,618/year)/[(50 lb-VOC/year)(1 ton/2000 lb)] 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-30 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

 = $384,720/ton of VOC reduced

As shown above, the costs for converting existing poultry housing to manure-belt 

housing would cause the cost of the VOC reductions to be greater than $384,720/ton. 

This may not include the costs of additional energy required to run the belt and any 

associated drying equipment. It is clear that the cost of the VOC emission reductions 

achieved are far beyond BARCT and any applicable RACT requirements. 

B. Composting or Storing Manure Removed Animal Housing in an Aerated 

Static Pile (ASP) or Enclosure Vented to a Control Device 

The costs associated with composting or storing the solid manure produced by livestock 

in an aerated static pile (ASP) vented to a control device or an enclosure vented to a 

control device are analyzed below. This practice is only applicable to manure that is 

handled in solid form; therefore this analysis will evaluate this option only for dairy 

cattle, beef cattle, and poultry because these confined animal facilities can handle 

manure in solid form. Manure from swine facilities must be handled as a liquid or slurry 

unless significant amounts of bedding are added to allow handling as a semi-solid. The 

cost of these options was previously evaluated in the final staff report for District Rule 

4565 - Biosolids, Animal Manure, and Poultry Litter Operations (May 30, 2007). The 

relevant cost information will be taken from this staff report. The staff report for District 

Rule 4565 found that use of ASPs and in-vessel composting would have unreasonably 

high costs for existing composting facilities that have a throughput of less than 100,000 

wet tons per year. The vast majority of confined animal facilities produce much less 

manure than this; therefore, this option is not expected to be cost-effective for confined 

animal facilities. Although this option is not expected to be reasonably cost-effective, it 

will be evaluated below. 

 

Description of Control Technology

It may be possible to reduce emissions from solid manure by using an ASP or enclosure 

to compost or store the solid manure. ASPs are used in composting systems to speed 

up the compost process by forcing or drawing air through the material being composted. 

The material in an ASP is placed over perforated pipes that are connected to a blower 

to draw air from the pile. The air that is drawn from the pile can be sent to a VOC 

control device to reduce emissions. Large composting facilities can also use in-vessel 

composting systems, in which the composting process occurs in a building or other 

enclosure. The emissions from solid manure that is composted or stored in an 

enclosure can also be sent to a VOC control device. A complete enclosure is more 

expensive than an ASP but results in higher capture efficiency for emissions. As noted 

in the staff report for District Rule 4565, biofilters are the most commonly used VOC 

emission control device at composting facilities. This is because biofilters are 

significantly less expensive than other options used for the control of VOCs. As 

discussed above, biofilters utilize microbial activity to remove contaminants from a gas 

through biological oxidation. 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-31 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

It must be noted that although it may be possible to reduce VOC emissions from solid 

manure using an ASP or enclosure vented to a biofilter or other control device, recent 

studies at dairies and poultry facilities have indicated that VOC emissions from stored 

solid manure and poultry litter are very low while other studies have indicated that large 

composting operations can have high VOC emissions if they are not properly controlled. 

Therefore, if composting is performed additional monitoring of the composting system 

and control device would be needed to ensure that VOC emissions are reduced 

compared to storage of solid manure. 

Cost of an ASP or Enclosure vented to a Control Device:

The following costs are taken from the final staff report for District Rule 4565 - Biosolids, 

Animal Manure, and Poultry Litter Operations (May 30, 2007).12 The cost information is 

based on a large composting facility with a throughput of 200,000 wet tons per year. On 

a per ton basis the costs for smaller composting facilities would be higher since there 

would not be the economies of scale for building and operations created by large 

composting facilities. 

Table 11 - Low Cost Scenario: ASP & Biofilter (200,000 wet ton/yr) 

Total Capital Cost $7,775,000 

Annualized capital cost 

(10% interest - 10 years) $1,265,345 

Total Annual O & M Cost $124,305 

Total Annualized Cost - ASP & Biofilter 

(Low-Estimate of Annual Costs) ($/yr/facility) $1,389,650 

Table 12 - High Cost Scenario: In-Vessel and RTO (200,000 wet ton/yr)

Total Capital Cost $21,185,000 

Annualized capital cost 

(10% interest - 10 years) $3,447,761 

Total Annual O & M Cost $285,910 

Total Annualized Cost - In-Vessel & RTO 

(High-Estimate of Annual Costs) ($/yr/facility) $3,733,671 

As stated above, the final staff report for District Rule 4565 stated that the use of ASPs 

and in-vessel composting would have unreasonably high costs for facilities that have a 

 

12 The capitol and operation costs for ASP and in-vessel composting given in the final staff report were 

taken from: United States Environmental Protection Agency, “Biosolids Technology Fact Sheet: Use of 

Composting for Biosolids Management” EPA 832-F-02-024, September 2002, 

http://water.epa.gov/scitech/wastetech/upload/2002_10_15_mtb_combioman.pdf. These costs were not 

adjusted for inflation 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

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Revised Proposed Amendments to Rule 4570 

throughput of less than 100,000 wet tons per year. The costs given above are for a 

facility with a throughput of 200,000 wet tons per year. It will conservatively be 

assumed that the cost for a facility with a throughput of 100,000 wet tons per year will 

be half of the values given above. Therefore, the cost estimates for a facility with a 

throughput of 100,000 are as follows: 

Low Annual Capital Cost Estimate (100,000 wet ton/yr) = $694,825/year 

High Annual Capital Cost Estimate (100,000 wet ton/yr) = $1,866,836/year 

a. ASP or In-Vessel Enclosure for Solid Cow Manure Removed from Housing 

The cost of the emission reductions achieved by composting or storing solid manure 

removed from dairy cow housing in an ASP or enclosure vented to a control device are 

analyzed below. Because it has been determined that this practice would not be costeffective for a facility with a throughput of less than 100,000 tons per year, this analysis 

will be based on a dairy facility that can produce 100,000 tons of solid manure per year. 

Number of Cows to Produce 100,000 ton/yr of Solid Manure

According to the United States Department of Agriculture (USDA) Natural Resources 

Conservation Service (NRCS) Agricultural Waste Management Field Handbook 

(AWMFH), Chapter 4 - Agricultural Waste Characteristics13 (March 2008), dairy cows in 

scraped open corrals produce approximately 77 lb per day of solid manure that can be 

removed and transferred for storage or composting. The amount of solid manure 

removed for dairy cows housed in corrals or freestall barns with a flush system would be 

much less. The number of cows needed to produce 100,000 ton/year of solid manure is 

calculated as follows: 

(100,000 ton/year x 2,000 lb/ton) ÷ (77 lb/cow-day x 365 day/yr) = 7,116 cows 

VOC Emission Reductions from an ASP or Enclosure Handling Solid Manure from 

7,116 Milk Cows:

The annual VOC Emission Reductions for ASP or in-vessel enclosure handling the solid 

manure from 7,116 milk cows are calculated as follows and shown in the table below: 

[Number of cows] x [Solid Manure VOC EF (lb/cow-year)] x [ASP/In-Vessel Capture 

Efficiency] x [Control Device VOC Control Efficiency] 

 

13 United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) 

Agricultural Waste Management Field Handbook (AWMFH), 

http://policy.nrcs.usda.gov/viewerFS.aspx?hid=21430 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-33 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Table 13 - VOC Reductions for Dairy Solid Manure in ASP or Enclosure Vented to a Biofilter 

Type of Animal # of 

cows 

x 

Solid Manure 

EF (lb/cow-yr) x Capture (%)* x 

Control 

(%) = lb-VOC/yr 

Milk Cow 7,116 x 0.15 x 50% x 85% = 454 

* The capture efficiency is conservatively assumed to be 50%. The technical assessment of SCAQMD 

Rule 1133.2 and the staff report for District Rule 4565 give a capture efficiency of 33% for composting 

facilities, which would result in lower emission reductions. 

Cost of VOC Emission Reductions

Low Estimate = ($694,825/year)/[(454 lb-VOC/year)(1 ton/2000 lb)] 

 = $3,060,903/ton of VOC reduced

High Estimate = ($1,866,836/year)/[(454 lb-VOC/year)(1 ton/2000 lb)] 

 = $8,223,947/ton of VOC reduced

As shown above, the cost an ASP or in-vessel enclosure to handle the solid manure at 

a dairy would cause the cost of the VOC reductions to be greater than $3,060,903/ton. 

The excessively high costs of this option make it impractical for most confined animal 

facilities. 

b. ASP or In-Vessel Enclosure for Feedlot Cattle Solid Manure Removed from 

Housing 

The cost of the emission reductions achieved by composting or storing solid manure 

removed from feedlot cattle pens in an ASP or enclosure vented to a control device are 

analyzed below. Because it has been determined that this practice would not be costeffective for a facility with a throughput of less than 100,000 tons per year, this analysis 

will be based on a feedlot facility that can produce 100,000 tons of solid manure per 

year. 

Number of Feedlot Cattle to Produce 100,000 ton/yr of Solid Manure

According to the United States Department of Agriculture (USDA) Natural Resources 

Conservation Service (NRCS) Agricultural Waste Management Field Handbook 

(AWMFH), Chapter 4 - Agricultural Waste Characteristics (March 2008), feedlot cattle in 

earthen lots produce approximately 17 lb per day of solid manure that can be removed 

and transferred for storage or composting. The number of feedlot cattle needed to 

produce 100,000 ton/year of solid manure is calculated as follows: 

(100,000 ton/year x 2,000 lb/ton) ÷ (17 lb/head-day x 365 day/yr) = 32,232 head 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-34 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

VOC Emission Reductions from an ASP or Enclosure Handling Solid Manure from 

32,232 Feedlot Cattle:

The annual VOC Emission Reductions for ASP or in-vessel enclosure handling the solid 

manure from 32,232 feedlot cattle are calculated as follows and shown in the table 

below: 

[Number of Feedlot Cattle] x [Solid Manure VOC EF (lb/head-year)] x [ASP/In-Vessel 

Capture Efficiency] x [Control Device VOC Control Efficiency] 

Table 14 - VOC Reductions for Feedlot Solid Manure in ASP or Enclosure Vented to a Biofilter 

Type of Animal # of 

head x 

Solid Manure EF 

(lb/head-yr)* x Capture (%)** x 

Control 

(%) = lb-VOC/yr 

Feedlot Cattle 32,232 x 0.09 x 50% x 85% = 1,233 

*Feedlot Cattle Solid manure EF estimated by scaling down the draft Dairy solid manure EF of 0.15 lb/hdyr based on current dairy and feedlot cattle VOC emission factors of 19.3 lb/hd-yr and 11.1 lb/hd-yr 

** The capture efficiency is conservatively assumed to be 50%. The technical assessment of SCAQMD 

Rule 1133.2 and the staff report for District Rule 4565 give a capture efficiency of 33% for composting 

facilities, which would result in lower emission reductions. 

Cost of VOC Emission Reductions

Low Estimate = ($694,825/year)/[(1,233 lb-VOC/year)(1 ton/2000 lb)] 

 = $1,127,048/ton of VOC reduced

High Estimate = ($1,866,836/year)/[(1,233 lb-VOC/year)(1 ton/2000 lb)] 

 = $3,028,120/ton of VOC reduced

As shown above, the cost an ASP or in-vessel enclosure to handle the solid manure at 

a feedlot would cause the cost of the VOC reductions to be greater than $1,127,048/ton. 

The excessively high costs of this option make it impractical for most confined animal 

facilities. 

c. ASP or In-Vessel Enclosure for Litter/Solid Manure Removed from Poultry 

Housing 

The cost of the emission reductions achieved by composting or storing litter/solid 

manure removed from poultry houses in an ASP or enclosure vented to a control device 

are analyzed below. Because it has been determined that this practice would not be 

cost-effective for a facility with a throughput of less than 100,000 tons per year, this 

analysis will be based on a broiler or turkey facility that can produce 100,000 tons of 

litter per year. However, it is thought that there are no single poultry facilities that are 

this large because of bio-security concerns and the impracticality of having such a large 

number of birds at one location. 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-35 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Number of Broilers or Turkeys to Produce 100,000 ton/yr of Litter

According to the United States Department of Agriculture (USDA) Natural Resources 

Conservation Service (NRCS) Agricultural Waste Management Field Handbook 

(AWMFH), Chapter 4 - Agricultural Waste Characteristics (March 2008), the amount of 

litter removed from poultry houses that can be transferred for storage or composting is 

approximately 0.044 lb per day for broilers and approximately 0.24 lb per day for 

turkeys. The number of broilers or turkeys needed to produce 100,000 ton/year of solid 

manure is calculated as follows: 

Broilers

(100,000 ton/year x 2,000 lb/ton) ÷ (0.044 lb/bird-day x 365 day/yr) = 12,453,300 birds 

Turkeys

(100,000 ton/year x 2,000 lb/ton) ÷ (0.24 lb/bird-day x 365 day/yr) = 2,283,105 birds 

As mentioned above, it is thought that there actually no poultry facilities with this 

number of broilers or turkeys at one location. Therefore, this option is not expected to 

be cost effective for any poultry facilities. The cost effectiveness for any poultry facilities 

that are this size is evaluated below. 

VOC Emission Reductions from an ASP or Enclosure Handling Litter/Solid Manure from 

12,453,300 Broilers or 2,283,105 Turkeys:

The annual VOC Emission Reductions for ASP or in-vessel enclosure handling the 

litter/solid manure from 12,453,300 broilers or 2,283,105 turkeys are calculated as 

follows and shown in the table below: 

[Number of Birds] x [Solid Manure VOC EF (lb/bird-year)] x [ASP/In-Vessel Capture 

Efficiency] x [Control Device VOC Control Efficiency] 

Table 15 - VOC Reductions for Poultry Solid Manure/Litter in ASP or Enclosure Vented to a Biofilter

Type of Animal # of Birds x 

Solid Manure EF 

(lb/bird-yr)* x Capture (%)** x 

Control 

(%) = lb-VOC/yr 

Broiler/Layer 12,453,300 x 0.0025 x 50% x 85% = 13,232 

Turkey 2,283,105 x 0.01 x 50% x 85% = 9,703 

* CARB source test results for California broiler houses indicated near negligible VOC emissions from 

litter when birds were not in the house.14 Based on the information from this study VOC emissions from 

poultry litter/solid manure removed from the house are very conservatively estimated to be 10% of the 

total VOC emission factor for poultry. 

** The capture efficiency is conservatively assumed to be 50%. The technical assessment of SCAQMD 

Rule 1133.2 and the staff report for District Rule 4565 give a capture efficiency of 33% for composting 

facilities, which would result in lower emission reductions. 

 

14 “Quantification of Gaseous Emissions from California Broiler Production Houses” - Source tests on 

mechanically ventilated broiler houses during the spring and fall of 2004. Participants included: AIRx 

Testing; California Air Resources Board; California Department of Food and Agriculture; California Poultry 

Federation; Foster Farms; & University of California, Davis. http://www.arb.ca.gov/ag/caf/poulemisrpt.pdf 
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 E-36 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Cost of VOC Emission Reductions

 Broilers/Layers

Low Estimate = ($694,825/year)/[(13,232 lb-VOC/year)(1 ton/2000 lb)] 

 = $105,022/ton of VOC reduced

High Estimate = ($1,866,836/year)/[(13,232 lb-VOC/year)(1 ton/2000 lb)] 

 = $282,170/ton of VOC reduced

 Turkeys

Low Estimate = ($694,825/year)/[(9,703 lb-VOC/year)(1 ton/2000 lb)] 

 = $143,219/ton of VOC reduced

High Estimate =($1,866,836/year)/[(9,703 lb-VOC/year)(1 ton/2000 lb)] 

 = $384,796/ton of VOC reduced

As shown above, there are no known poultry facilities that are large enough for use of 

ASP or in-vessel enclosure to handle the litter/solid manure to be cost effective. If there 

were any such facilities the cost of the VOC reductions would be greater than 

$105,022/ton for broilers and greater than $143,219/ton for turkeys. The excessively 

high costs of this option make it impractical for most confined animal facilities 

C. Sending Solid Manure Removed from Animal Housing to a Digester with a 

VOC Control Device 

The costs associated with treating the solid manure produced by livestock in a digester 

vented to a control device are analyzed below. This practice is only applicable to 

manure that is handled in solid form; therefore this cost analysis will evaluate this option 

only for dairy cattle, beef cattle, and poultry because these confined animal facilities can 

handle manure in solid form. Manure from swine facilities must be handled as a liquid 

or slurry unless significant amounts of bedding is added, which would preclude effective 

use of a digester. For solid manure, complete-mix and plug flow digesters can be used. 

Plug flow digesters are primarily used with cattle manure because the high solids 

content and fibrous material in cattle manure allows the manure to be effectively pushed 

through the digester. EPA’s AgSTAR anaerobic digester database lists a number of 

digesters utilizing dairy manure but only two digesters using beef cattle manure and 

three using poultry manure.15 This is because manure from beef cattle and broilers is 

usually mixed with large amount of bedding or earth and cannot be easily collected and 

separated for use in a digester. 

 

 

15 US EPA AgSTAR Program Guide to Anaerobic Digesters – Anaerobic Digester Database (updated 

April 2010), http://www.epa.gov/agstar/operational.html 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

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Revised Proposed Amendments to Rule 4570 

Description of Control Technology

An anaerobic digester is an enclosed basin or tank that is designed to facilitate the 

decomposition of wastewater by microbes in the absence of oxygen. The process of 

anaerobic decomposition results in the conversion of organic compounds in the 

wastewater into methane (CH4), carbon dioxide (CO2), and water rather than 

intermediate Volatile Organic Compounds (VOCs). The gas generated by this process 

is known as biogas, waste gas, or digester gas. Biogas may also include trace amounts 

of VOCs that remain from incomplete digestion of the volatile solids in the incoming 

wastewater. The undigested solids that remain after digestion are removed from the 

digester as sludge. Because biogas is mostly composed of methane, the main 

component of natural gas, the gas produced in the digester can be cleaned to remove 

H2S and other impurities and used as fuel. The captured biogas can be combusted in a 

flare or may be sent to a boiler or engine, where the gas can be used to generate useful 

heat or electrical energy. 

As stated above, the gas generated from the solid manure sent to an anaerobic digester 

can be captured and then sent to a suitable combustion device. During combustion, 

gaseous hydrocarbons are oxidized to form CO2 and water. For this analysis, the 

overall control efficiency is assumed to be 80% of the emissions that would have been 

emitted from the solid manure piles. 

a. Digester for Solid Manure from Dairy Cows 

The costs associated with treating the solid manure removed from milk cow housing in a 

plug flow digester vented to a control device are analyzed below. Because it may be 

possible to generate power from the system to offset some of the costs associated with 

installation, this potential benefit is included in the analysis below. The following 

analysis is based on the treatment of solid manure from 1,000 milk cows in a plug flow 

digester with power generation. 

Capital Cost for Installation of a Plug Flow Digester for Dairy Cows

The capital cost estimates for installation of a plug flow digester are based on information 

from the United States EPA AgSTAR publication “Anaerobic Digestion Capital Costs for 

Dairy Farms” (May 2010)16 and the California Energy Commission (CEC) Public Interest 

Energy Research (PIER) Program Dairy Methane Digester System Program Evaluation 

Report (Feb 2009)17. The formula in the AgSTAR publication results in a capitol cost of 

$1,192 per cow for a plug flow anaerobic digester treating manure from 1,000 cows. 

This estimate excludes costs of solids separation after digestion, hydrogen sulfide 

 

16 “Anaerobic Digestion Capital Costs for Dairy Farms” (May 2010), EPA AgSTAR 

http://www.epa.gov/agstar/pdf/digester_cost_fs.pdf 17 “Dairy Power Production Program – Dairy Methane System Program Evaluation Report” (February 

2009). Western United Resource Development, Inc prepared for the California Energy Commission (CEC) 

Public Interest Energy Research Program. (CEC-500-2009-009) 

http://www.energy.ca.gov/2009publications/CEC-500-2009-009/CEC-500-2009-009.PDF 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-38 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

removal, and utility charges including line upgrades and interconnection costs and fees. 

Based on information from installations in California, the CEC PIER Dairy Methane 

Digester Program Evaluation Report gives an average cost of $1,042 per cow for 

installation of plug flow anaerobic digesters (see Table 9 - Total Project Costs and Cost 

per Cow and per kW). Therefore, for purposes of this analysis the capital cost for 

installation of a plug flow digester system for 1,000 cows will be assumed to be between 

$1,042 and $1,192 per cow. The capital cost estimates of a plug flow digester treating 

the manure of 1,000 milk cows are shown below: 

Low capital cost estimate: $1,042/cow x 1,000 cows = $1,042,000 

High capital cost estimate: $1,192/cow x 1,000 cows = $1,192,000 

The annualized capital cost estimates will be calculated below. The capital cost for the 

installation of the plug flow digester will be spread over the expected life of the system 

using the capital recovery equation. The expected life of the entire system will be 

estimated at 10 years though the cover may require replacement during this period. A 

10% interest rate is assumed in the equation and the assumption will be made that the 

equipment has no salvage value at the end of the ten-year cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Low Annual Capital Cost Estimate = 

[$1,042,000 x 0.1(1.1)10]/[(1.1)10-1] = $169,581/year

High Annual Capital Cost Estimate = 

[$1,192,000 x 0.1(1.1)10]/[(1.1)10-1] = $193,993/year 

Potential Production of Electricity from a Plug Flow Digester Treating Solid Manure from 

1,000 Milk Cows:

It may be possible to offset some of the installation costs of an anaerobic digester with 

revenue from generation of electricity. Based on the information given in the CEC PIER 

Dairy Methane Digester Program Evaluation Report, Table 7 – Actual Generation per 

Cow Comparisons, California dairies that used a plug flow digester to produce electricity 

generated between 426.5 and 1,013.2 kW-hr/yr per lactating cow with a overall per 

facility average generation rate of 632.8 kW-hr/yr per lactating cow. This average 

annual generation rate is actually higher than all the facilities included in the average 

except one that had a very high generation rate. In addition, this average may 

overestimate the per-cow generation potential because the contributions of support 

stock to the digesters were not accounted for. However, for more conservative 

calculations, this average will be used to calculate the potential annual savings in 

electricity costs. The potential production of electricity from a plug flow digester treating 

solid manure from 1,000 milk cows is calculated as follows: 

Electrical Production: 632.8 kW-hr/(milk cow-yr) x 1,000 milk cows 

= 632,800 kW-hr/yr 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-39 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Potential Cost Savings from Production of Electricity from a Plug Flow Digester Treating 

Solid Manure from 1,000 Milk Cows:

The value of the electricity generated will be based upon the average price for industrial 

electricity in California for the year 2010, as taken from the Energy Information 

Administration (EIA) Website: 

(http://www.eia.doe.gov/cneaf/electricity/epm/table5_6_b.html) 

Average Cost for electricity = $0.0999/kW-hr 

The potential annual cost savings from electricity generation from a plug flow digester 

treating manure from 1,000 milk cows is calculated as follows: 

632,800 kW-hr/yr x $0.0999/kW-hr = $63,217/yr 

Annualized Capital Cost for a Plug Flow Digester Treating Solid Manure from 1,000 Milk 

Cows minus Potential Savings from Generation of Electricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation 

= $169,581/yr - $63,217/yr = $106,364/year

High Annual Capital Cost Estimate minus Savings from Potential Generation 

= $193,993/yr - $63,217/yr = $130,776/year 

VOC Emission Reductions from a Plug Flow Anaerobic Digester Treating Solid Manure 

from 1,000 Milk Cows:

The annual VOC Emission Reductions for plug flow anaerobic digester treating the solid 

manure from 1,000 milk cows are calculated as follows and shown in the table below: 

[Number of cows] x [Solid Manure VOC EF (lb/cow-year)] x [Digester Control Efficiency 

for Solid Manure] 

Table 16 - VOC Reductions for a Digester for Solid Manure Vented to Control Device

Type of Cow # of 

cows 

x 

Solid Manure EF 

(lb/cow-yr) x 

Control 

(%) = lb-VOC/yr 

Milk Cow (freestall) 1,000 x 0.15 x 80% = 120 

Cost of VOC Emission Reductions

Low Estimate = ($106,364/year)/[(120 lb-VOC/year)(1 ton/2000 lb)] 

 = $1,772,733/ton of VOC reduced 

High Estimate = ($130,776/year)/[(120 lb-VOC/year)(1 ton/2000 lb)] 

 = $2,179,600/ton of VOC reduced

As shown above, the capital cost alone for a digester to treat the solid manure at a dairy 

would cause the cost of the VOC reductions to be greater than $1,772,733/ton. This 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-40 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

cost includes the potential revenue generated by electrical production but does not 

include the additional maintenance required for the system. Even without these costs, it 

is clear that the cost of the VOC emission reductions achieved are far beyond BARCT 

and any applicable RACT requirements. This analysis did not consider the additional 

pollution that would be generated by any combustion equipment that would utilize the 

gas, which may offset any reductions in VOCs. 

b. Digester for Solid Manure from Feedlot Cattle 

The costs associated with treating the solid manure removed from feedlot cattle housing 

in a plug flow digester vented to a control device are analyzed below. Because it may 

be possible to generate power from the system to offset some of the costs associated 

with installation, this potential benefit is included in the analysis below. The following 

analysis is based on the treatment of solid manure from 3,500 feedlot cattle in a plug 

flow digester with power generation. 

Capital Cost for Installation of a Plug flow Digester for Feedlot Cattle

On an animal weight basis, the capital cost estimates for installation of a plug flow digester 

for beef feedlot cattle are assumed to be the same as the costs for installation of a plug 

flow digester at a dairy. Based on the information given above, the capital cost of 

installation of a plug flow digester at a dairy is between $1,042 and $1,192 per cow. A 

typical milk cow weighs approximately 1,400 lb and the average weight of feedlot steers is 

assumed to be 950 lb. The estimated capital cost of a plug flow digester for beef feedlot 

cattle is estimated by adjusting by weight as follows: 

Low capital cost estimate: $1,042/cow x 950 lb/head/(1,400 lb/cow) = $707/head 

High capital cost estimate: $1,192/cow x 950 lb/head/(1,400 lb/cow) = $809/head 

The estimated capital cost of a plug flow digester treating the solid manure from 3,500 

finishing steers is calculated as follows: 

Low capital cost estimate: 3,500 head x $707/head = $2,474,500 

High capital cost estimate: 3,500 head x $809/head = $2,831,500 

The annualized capital cost estimates will be calculated below. The capital cost for the 

installation of the plug flow digester will be spread over the expected life of the system 

using the capital recovery equation. The expected life of the entire system will be 

estimated at 10 years though the cover may require replacement during this period. A 

10% interest rate is assumed in the equation and the assumption will be made that the 

equipment has no salvage value at the end of the ten-year cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Low Annual Capital Cost Estimate = [$2,474,500 x 0.1(1.1)10]/[(1.1)10-1] 

 = $402,713/year 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-41 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

High Annual Capital Cost Estimate = [$2,831,500 x 0.1(1.1)10]/[(1.1)10-1] 

 = $460,814/year 

Potential Production of Electricity from a Plug flow Digester Treating Solid Manure from 

3,500 Beef Feedlot Cattle:

It may be possible to offset some of the installation costs of a plug flow anaerobic 

digester with revenue from generation of electricity. Production of electricity from 

digester gas from feedlot cattle manure has not been common because of the difficulty 

in collecting fresh manure for a digester. Because there is limited information available 

regarding production of electricity from digester gas from feedlot cattle manure, the 

potential for production of electricity will be estimated based on the information given 

above for production of electricity from plug flow digesters at dairy facilities. It will be 

assumed that the potential for production of digester gas and electricity from dairy cows 

and beef cattle will be proportional to the amount of volatile solids excreted in the 

manure. According to the United States Department of Agriculture (USDA) Natural 

Resources Conservation Service (NRCS) Agricultural Waste Management Field 

Handbook (AWMFH), Chapter 4 - Agricultural Waste Characteristics18 (March 2008), a 

lactating dairy cow excretes an average of approximately 17 lb/day of volatile solids and 

feedlot cattle excrete an average of approximately 9.35 lb/day of volatile solids per 

1,000-lb AU. Based on the information given above, a plug flow anaerobic digester at a 

dairy is estimated to produce 670.3 kW-hr per milk cow per year. Assuming that the 

amount of electricity produced is proportional to the amount of volatile solids sent to the 

plug flow digester, the potential for electricity generation by a plug flow anaerobic 

digester at a beef cattle facility is estimated as follows: 

(0.95 AU/head x 9.35 lb VS/AU)/(17 lb-VS/milk cow) x 632.8 kW-hr/(milk cow-yr) 

= 330.6 kW-hr/(head-yr) 

The potential production of electricity from a plug flow digester treating solid manure from 

3,500 beef feedlot cattle is calculated as follows: 

Electrical Production: 330.6 kW-hr/(head-yr) x 3,500 head = 1,157,100 kW-hr/yr 

Potential Cost Savings from Production of Electricity from a Plug Flow Digester Treating 

Solid Manure from 3,500 Feedlot Cattle:

Based on the reference given above, the value of electricity used for this analysis will be 

= $0.0999/kW-hr 

The potential annual cost savings from electricity generation from a plug flow digester 

treating manure from 3,500 feedlot cattle is calculated as follows: 

1,157,100 kW-hr/yr x $0.0999/kW-hr = $115,594/yr 

 

18 United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) 

Agricultural Waste Management Field Handbook (AWMFH), 

http://policy.nrcs.usda.gov/viewerFS.aspx?hid=21430 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-42 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Annualized Capital Cost for a Plug flow Digester Treating Solid Manure from 3,500 

Feedlot Cattle minus Potential Savings from Generation of Electricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation 

= $402,713/yr - $115,594/yr = $287,119/year

High Annual Capital Cost Estimate minus Savings from Potential Generation 

= $460,814/yr - $115,594/yr = $345,220/year 

VOC Emission Reductions from a Plug flow Anaerobic Digester Treating Solid Manure 

from 3,500 Feedlot Cattle:

The annual VOC Emission Reductions for plug flow anaerobic digester treating the 

manure from 3,500 feedlot cattle are calculated as follows and shown in the table 

below: 

[Number of Feedlot Cattle] x [Solid Manure VOC EF (lb/cow-year)] x [Digester Control 

Efficiency for Solid Manure] 

Table 17 - VOC Reductions for a Plug Flow Digester Vented to Control Device 

Type of Animal # of 

head x 

Solid Manure EF 

(lb/head-yr) x 

Control 

(%) = lb-VOC/yr 

Feedlot Cattle 3,500 x 0.09 x 80% = 252 

* Based on scaling down draft dairy emission factor for solid manure using current dairy and feedlot 

cattle VOC emission factors of 19.3 lb/hd-yr and 11.1 lb/hd-yr

Cost of VOC Emission Reductions

Low Estimate = ($287,119/year)/[(252 lb-VOC/year)(1 ton/2000 lb)] 

 = $2,278,722/ton of VOC reduced

High Estimate = ($345,220/year)/[(252 lb-VOC/year)(1 ton/2000 lb)] 

 = $2,739,841/ton of VOC reduced

As shown above, the capital cost alone for a digester to treat the solid manure at a beef 

feedlot would cause the cost of the VOC reductions to be greater than $2,278,722/ton. 

This cost includes the potential revenue generated by electrical production but does not 

include the additional maintenance required for the system. Even without these costs, it 

is clear that the cost of the VOC emission reductions achieved are far beyond BARCT 

and any applicable RACT requirements. This analysis did not consider the additional 

pollution that would be generated by any combustion equipment that would utilize the 

gas, which may offset any reductions in VOCs. 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-43 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

c. Digester for Solid Manure from Poultry 

Although treating the manure excreted by poultry in a digester is not a common 

practice19, the costs associated with treating the solid manure excreted by laying hens 

in a digester are analyzed below. Because it may be possible to generate power from 

the system to offset some of the costs associated with installation, this potential benefit 

is included in the analysis below. The following analysis is based on the treatment of 

manure from 500,000 laying hens in an anaerobic digester with power generation. 

Capital Cost for Installation of a Digester for Poultry Solid Manure

On an animal weight basis, the capital cost estimates for installation of a digester treating 

solid manure from poultry are assumed to be the same as the costs for installation of a 

plug flow digester at a dairy. Based on the information given above, the capital cost of 

installation of a plug flow digester at a dairy is between $1,042 and $1,192 per cow. A 

typical milk cow weighs approximately 1,400 lb and the average weight of a laying hen is 

assumed to be 4 lb. The estimated capital cost of a digester for solid poultry manure is 

estimated by adjusting by weight as follows: 

Low capital cost estimate: $1,042/cow x 4 lb/bird/(1,400 lb/cow) = $2.98/bird 

High capital cost estimate: $1,192/cow x 4 lb/bird/(1,400 lb/cow) = $3.41/bird 

The estimated capital cost of a plug flow digester treating the solid manure from 500,000 

laying hens is calculated as follows: 

Low capital cost estimate: 500,000 birds x $2.98/bird = $1,490,000 

High capital cost estimate: 500,000 birds x $3.41/bird = $1,705,000 

The annualized capital cost estimates will be calculated below. The capital cost for the 

installation of the digester will be spread over the expected life of the system using the 

capital recovery equation. The expected life of the entire system will be estimated at 10 

years though the cover may require replacement during this period. A 10% interest rate 

is assumed in the equation and the assumption will be made that the equipment has no 

salvage value at the end of the ten-year cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Low Annual Capital Cost Estimate = [$1,490,000 x 0.1(1.1)10]/[(1.1)10-1] 

 = $242,491/year

High Annual Capital Cost Estimate = [$1,705,000 x 0.1(1.1)10]/[(1.1)10-1] 

 = $277,481/year 

 

19 The US EPA AgSTAR Program Guide to Anaerobic Digesters – Anaerobic Digester Database (updated 

April 2010) lists only three poultry digesters, http://www.epa.gov/agstar/operational.html 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-44 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Potential Production of Electricity from an Anaerobic Digester Treating Solid Manure 

from 500,000 Laying Hens:

It may be possible to offset some of the installation costs of an anaerobic digester with 

revenue from generation of electricity. Because only a very small number of digesters 

have been installed at poultry facilities and there is limited information available 

regarding production of electricity from digester gas from poultry manure, the potential 

for production of electricity will be estimated based on the information given above for 

production of electricity from plug-flow digesters at dairy facilities. It will be assumed 

that the potential for production of digester gas and electricity from dairy cows and 

poultry will be proportional to the amount of volatile solids excreted in the manure. 

According to the USDA NRCS Agricultural Waste Management Field Handbook 

(AWMFH), Chapter 4 - Agricultural Waste Characteristics (March 2008), a lactating 

dairy cow excretes an average of approximately 17 lb/day of volatile solids and a laying 

hen excretes approximately 0.036 lb/day of volatile solids. Based on the information 

given above, an anaerobic digester treating solid manure at a dairy is estimated to 

produce 632.8 kW-hr per milk cow per year. Assuming that the amount of electricity 

produced is proportional to the amount of volatile solids sent to the plug flow, the 

potential for electricity generation by an anaerobic digester for solid manure at a poultry 

facility is estimated as follows: 

(0.036 lb-VS/bird)/(17 lb-VS/milk cow) x 632.8 kW-hr/(milk cow-yr) = 1.34 kWhr/(bird-yr) 

The potential production of electricity from a digester treating solid manure from 500,000 

laying hens is calculated as follows: 

Electrical Production: 1.34 kW-hr/(bird-yr) x 500,000 birds = 670,000 kW-hr/yr 

Potential Cost Savings from Production of Electricity from a Digester Treating Solid 

Manure from 500,000 Laying Hens:

Based on the reference given above, the value of electricity used for this analysis will be 

= $0.0999/kW-hr 

The potential annual cost savings from electricity generation from a digester treating 

solid manure from 500,000 laying hens is calculated as follows: 

670,000 kW-hr/yr x $0.0999/kW-hr = $66,933/yr 

Annualized Capital Cost for a Digester Treating Solid Manure from 500,000 Birds minus 

Potential Savings from Generation of Electricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation 

= $242,491//yr - $66,933/yr = $175,558/year 

High Annual Capital Cost Estimate minus Savings from Potential Generation 

= $277,481/yr - $66,933/yr = $210,548/year 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-45 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

VOC Emission Reductions from an Anaerobic Digester Treating Solid Manure from 

500,000 Birds:

The annual VOC Emission Reductions for an anaerobic digester treating the solid 

manure from 500,000 birds are calculated as follows and shown in the table below: 

[Number of Birds] x [Solid Manure VOC EF (lb/cow-year)] x [Digester Control Efficiency 

for Solid Manure] 

Table 18 - VOC Reductions for a Digester for Solid Manure Vented to Control Device

Animal # of Birds x Lagoon EF 

(lb/Bird-yr)* x 

Control 

(%) = lb-VOC/yr 

Laying Hens 500,000 x 0.0025 x 80% = 1,000 

* CARB source test results for California broiler houses indicated near negligible VOC emissions from 

litter when birds were not in the house.20 Based on the information from this study VOC emissions from 

poultry litter/solid manure removed from the house are very conservatively estimated to be 10% of the 

total VOC emission factor for poultry. 

Cost of VOC Emission Reductions

Low Estimate = ($175,558/year)/[(1,000 lb-VOC/year)(1 ton/2000 lb)] 

 = $351,116/ton of VOC reduced

High Estimate =($210,548/year)/[(1,000 lb-VOC/year)(1 ton/2000 lb)] 

 = $421,096/ton of VOC reduced

As shown above, the capital cost alone for an anaerobic digester for solid manure from 

poultry would cause the cost of the VOC reductions to be greater than $351,116/ton. 

This cost includes the potential revenue generated by electrical production but does not 

include the additional maintenance required for the system. Even without these costs, it 

is clear that the cost of the VOC emission reductions achieved are far beyond BARCT 

and any applicable RACT requirements. This analysis did not consider the additional 

pollution that would be generated by any combustion equipment that would utilize the 

gas, which may offset any reductions in VOCs. In general, this option would not likely 

be considered economically feasible for any facility without the project receiving 

substantial subsidies to offset the extremely high costs of installation. 

 

20 “Quantification of Gaseous Emissions from California Broiler Production Houses” - Source tests on 

mechanically ventilated broiler houses during the spring and fall of 2004. Participants included: AIRx 

Testing; California Air Resources Board; California Department of Food and Agriculture; California Poultry 

Federation; Foster Farms; & University of California, Davis. http://www.arb.ca.gov/ag/caf/poulemisrpt.pdf 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-46 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

D. Aerobic Treatment Lagoon or a Mechanically Aerated to Treat Manure 

Liquid Manure Produced by Livestock 

The feasibility of treating the manure produced by livestock in an aerobic lagoon is 

evaluated below. This practice is only applicable to manure that is handled in liquid 

form; therefore this option will only be evaluated for dairy cattle, swine, and layers 

because these confined animal facilities frequently handle manure in liquid form, 

whereas feedlot cattle, broilers and turkeys almost exclusively handle manure or litter as 

a solid. As defined in the current and proposed versions of District Rule 4570, an 

aerobic lagoon is “a lagoon designed, constructed, maintained, and operated in 

accordance with the applicable standards for aerobic lagoons in the Natural Resource 

Conservation Service (NRCS) California Field Office Technical Guide Conservation 

Practice Standard Code 359 or other applicable standards approved by the APCO, 

ARB, and EPA.” NRCS Practice Standard Code 359 contains criteria for both naturally 

aerobic lagoons and mechanically aerated lagoons. Because it is clear that the very 

large land requirements to treat the manure from confined animal facilities subject to 

this rule in a naturally aerobic lagoon are beyond what could reasonably be required, a 

complete cost analysis will not performed for this option. However, a complete cost 

analysis will be performed for a mechanically aerated lagoon. 

Description of Control Technology

An aerobic lagoon is a waste treatment lagoon that is designed to facilitate the 

decomposition of wastewater by microbes in the presence of oxygen (O2). The process 

of aerobic decomposition results in the conversion of organic compounds in the 

wastewater into carbon dioxide (CO2), and (H2O), nitrates, sulfates, and inert biomass 

(sludge). The process of aerobic digestion is sometimes referred to as nitrification 

(especially when discussing NH3 transformation). Complete aerobic digestion (100% 

aeration) removes nearly all malodors and also virtually eliminates VOCs, H2S, and NH3

emissions from liquid waste. 

In completely aerated lagoons sufficient oxygen must be provided to sustain the aerobic 

microorganisms. NRCS Practice Standard Code 359 specifies that naturally aerobic 

lagoons have a minimum surface area determined by regional climate and daily 

Biological Oxygen Demand (BOD5) and requires the depth of naturally aerobic lagoons 

have a maximum depth no greater than five feet. For mechanically aerated lagoons 

NRCS Practice Standard Code 359 specifies that the aeration equipment shall provide 

a minimum of 1 pound of oxygen for each pound of daily BOD5 loading. The 

mechanical aerators that provide the required oxygen may float on the lagoon surface or 

be submerged in the lagoon. Aeration can also be performed by injection of tiny air 

bubbles into the lagoon water, mixing of the lagoon water, or spraying of the water into 

the air. According to Dr. Ruihong Zhang, a researcher at the University of California, 

Davis, at least 95% VOC control can be achieved if the dissolved oxygen (DO) 

concentration of the liquid manure is 2.0 mg/L or more. However, the DO 

concentrations achieved in mechanically aerated lagoons treating manure are typically 
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 E-47 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

much less than this and will therefore have lower control efficiencies. A major 

disadvantage of completely aerated lagoons is the enormous cost of the energy 

required to run the aerators continuously. Because of this, it has generally been 

determined that completely aerated lagoons are not cost effective options for confined 

animal facilities at the present time. 

a. Aerobic Lagoon Treating Liquid Manure from Dairy Cows 

The following analyses are based on the treatment of manure from 1,000 milk cows in 

naturally aerobic lagoons and mechanically aerated lagoons. 

Space Requirement for a Naturally Aerobic Lagoon Treating Manure from 1,000 Dairy 

Cows

The following brief analysis will demonstrate that the very large land requirements 

needed to treat the manure from dairies subject to this rule in a naturally aerobic lagoon 

would be beyond what could reasonably be required. Therefore, there is no need to 

perform a detailed analysis that would consider all of the additional costs, such as the 

costs of purchasing additional land, constructing and lining the lagoon(s), and additional 

costs for control of mosquito larvae. 

NRCS Practice Standard Code 359 requires that naturally aerobic lagoons be designed 

to have a minimum treatment surface area as determined on the basis of daily BOD5

loading per unit of lagoon surface. The standard specifies that the maximum loading 

rate of naturally aerobic lagoons shall not exceed the loading rate indicated by the 

NRCS Agricultural Waste Management Field Handbook (AWMFH)21 or the maximum 

loading rate according to state regulatory requirements, whichever is more stringent. 

According to Figure 10-30 (August 2009) of the latest version of the AWMFH, the 

maximum aerobic lagoon loading rate for the San Joaquin Valley is 45 - 55 lbBOD5/acre-day. According to Table 4-5 (March 2008) of the NRCS AWMFH, the total 

daily manure produced by a milk cow will have 2.9 lb-BOD5/day. Assuming that 80% of 

the manure will be flushed to the lagoon system, the minimum lagoon surface area 

required for a naturally aerobic lagoon treating manure from 1,000 milk cows in the San 

Joaquin Valley can be calculated as follows: 

BOD5 loading (lb/day) = 1,000 milk cows x 2.9 lb-BOD5/cow-day x 0.80 

= 2,320 lb-BOD5/day 

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum 

loading rate of 55 lb-BOD5/acre-day = 

2,320 lb-BOD5/day ÷ 55 lb-BOD5/acre-day = 42.2 acres 

 

21 United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) 

Agricultural Waste Management Field Handbook (AWMFH), 

http://policy.nrcs.usda.gov/viewerFS.aspx?hid=21430 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-48 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum 

loading rate of 45 lb-BOD5/acre-day = 

2,320 lb-BOD5/day ÷ 45 lb-BOD5/acre-day = 51.6 acres 

As shown above the minimum surface area required for a naturally aerobic lagoon 

treating manure from 1,000 milk cows in the San Joaquin Valley would range from 

approximately 42.2 to 51.6 acres. This does not include the additional surface area that 

would be required to treat manure from support stock onsite. Based on the space 

requirements alone it is clear that this option cannot reasonably be required and no 

further analysis is needed. 

Analysis for a Mechanically Aerated Lagoon Treating Manure from 1,000 Dairy Cows

As discussed above, the very large space requirements for naturally aerobic lagoons 

cause this option to be infeasible for most confined animal facilities. Mechanically 

aerating a lagoon can achieve some of the benefits of a naturally aerobic lagoon without 

the large space requirements. However, the costs of energy for complete aeration have 

also caused this option to be infeasible. The amount of energy required for aeration is 

based on the amount of volatile solids excreted by animals that must be treated; thus, 

this cost will be directly proportional to the number of animals at a site. The following 

analysis will determine the cost of emission reductions that can be achieved from a 

mechanically aerated lagoon treating manure from 1,000 milk cows. 

Biological Oxygen Demand (BOD5)

In order to effectively calculate the costs of this control option, the energy requirement 

for complete aeration must be determined. It should be noted that approximately 1.5 to 

2.5 pounds of oxygen is required to digest 1 pound of Biological Oxygen Demand 

(BOD5) with additional oxygen required for conversion of ammonia to nitrate 

(nitrification).22 It is generally accepted that at least twice the BOD should be provided 

for complete aeration.23 According to Dr. Ruihong Zhang of the University of California, 

Davis, 2.4 lbs (1.1 kg) of oxygen (O2) per cow must be provided each day for removal of 

BOD and an additional 3 lbs (1.4 kg) per cow for oxidation of 70% of the nitrogen. 22 

The proposed rule specifies that an aerobic lagoon be designed and operated in 

accordance with NRCS Practice Standard Code 359. NRCS Practice Standard Code 

359 requires that mechanically aerated lagoons use aeration equipment that provides a 

minimum of one pound of oxygen for each pound of daily BOD5 loading. As discussed 

above, the total daily manure produced by a milk cow will have a BOD5 of 2.9 lb/day 

and a lagoon handling flushed manure from 1,000 milk cows will have a loading rate of 

approximately 2,320 lb-BOD5/day (1,052 kg-BOD5/day). 

 

22 An Assessment of Technologies for Management and Treatment of Dairy Manure in California’s San 

Joaquin Valley, December 2005, pages 34 & 35 (http://www.arb.ca.gov/ag/caf/dairypnl/dmtfaprprt.pdf) 23 See http://www.extension.org/faq/27574 and http://www.omafra.gov.on.ca/english/engineer/facts/04-

033.htm 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-49 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Energy Requirement a Mechanically Aerated Lagoon Treating Manure from 1,000 Milk 

cows:

Based on the data gathered in a UC Davis study on aerator performance for wastewater 

lagoons, aeration efficiencies for mechanical aerators ranged from 0.10 to 0.68 kg of 

oxygen provided per kW-hr of energy utilized.24 The most efficient aerator tested that 

had been installed in dairy lagoons had an aeration efficiency of 0.49 kg-O2/kW-hr. 

These efficiency tests were performed in clean water and lower aeration efficiencies are 

expected in liquid manure because of the significant amount of solids that it contains. 

The yearly energy requirement mechanically aerated lagoon treating flushed manure 

from 1,000 milk cows is calculated as follows: 

High Efficiency Aerator

1,052 kg-BOD5/day ÷ (0.68 kg-O2/kW-hr) x (365 day/year) = 564,676 kW-hr/year 

Low Efficiency Aerator

1,052 kg-BOD5/day ÷ (0.10 kg-O2/kW-hr) x (365 day/year) = 3,839,800kW-hr/year 

Cost of Electricity for a Mechanically Aerated Lagoon Treating Manure from 1,000 Milk 

cows:

The cost for electricity will be based upon the average price for industrial electricity in 

California for the year 2010, as taken from the Energy Information Administration (EIA) 

Website: (http://www.eia.doe.gov/cneaf/electricity/epm/table5_6_b.html) 

Average Cost for electricity = $0.0999/kW-hr 

The electricity costs for complete aeration are calculated as follows: 

Low Cost Estimate (High Efficiency Aerator)

564,676 kW-hr/year x $0.0999/kW-hr = $56,411/year

High Cost Estimate (Low Efficiency Aerator)

3,839,800 kW-hr/year x $0.0999/kW-hr = $383,596/year 

VOC Emission Reductions from a Mechanically Aerated Lagoon Treating Manure from 

1,000 Milk Cows:

It will be conservatively assumed that a mechanically aerated lagoon providing 1 lb of 

oxygen for every 1 lb of BOD5 loading will control 90% of the VOC emissions from the 

lagoon/storage pond. However, as noted above, it is generally accepted that the 

oxygen provided should be twice the BOD5 loading rate for complete aeration; 

therefore, the actual control from providing 1 lb of oxygen for every 1 lb of BOD5 loading 

is probably closer to 50%. 

 

24 Aerator Performance for Wastewater Lagoon Application, September 2007, UC Davis, R.H. Zhang 

(http://asae.frymulti.com/abstract.asp?aid=23832&t=2) 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-50 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

The annual VOC Emission Reductions for mechanically aerated lagoon treating the 

manure from 1,000 milk cows are calculated as follows and shown in the table below: 

[Number of cows] x [Lagoon/Storage Pond VOC EF (lb/cow-year)] x [Complete Aeration 

Control Efficiency for Lagoon/Storage Pond] 

Table 19 - VOC Reductions for a Mechanically Aerated Lagoon 

Type of Animal # of 

cows 

x Lagoon EF 

(lb/cow-yr) x 

Control 

(%) = lb-VOC/yr 

Milk Cow (freestall) 1,000 x 1.3 x 90% = 1,170 

Cost of VOC Emission Reductions

Low Estimate = ($56,411/year)/[(1,170 lb-VOC/year)(1 ton/2000 lb)] 

 = $96,429/ton of VOC reduced

High Estimate =($383,596/year)/[(1,170 lb-VOC/year)(1 ton/2000 lb)] 

 = $655,720/ton of VOC reduced

As shown above, the electricity cost alone for a mechanically aerated lagoon would 

cause the cost of the VOC reductions to be greater than $96,429/ton. This cost does 

not include the additional electricity cost for nitrification that would naturally occur as the 

lagoons were aerated or equipment costs. Even without these costs, it is clear that the 

cost of the VOC emission reductions achieved are far beyond BARCT and any 

applicable RACT requirements. 

b. Aerobic Lagoon Treating Liquid Manure from Swine 

The following analyses are based on the treatment of manure from 3,000 finishing 

swine in naturally aerobic lagoons and mechanically aerated lagoons. 

Space Requirement for a Naturally Aerobic Lagoon Treating Manure from 3,000 

Finishing Swine

The following brief analysis will demonstrate that the very large land requirements 

needed to treat the manure from swine facilities subject to this rule in a naturally aerobic 

lagoon would be beyond what could reasonably be required. Therefore, there is no 

need to perform a detailed analysis that would consider all of the additional costs, such 

as the costs of purchasing additional land, constructing and lining the lagoon(s), and 

additional costs for control of mosquito larvae. 

NRCS Practice Standard Code 359 requires that naturally aerobic lagoons be designed 

to have a minimum treatment surface area as determined on the basis of daily BOD5

loading per unit of lagoon surface. The standard specifies that the maximum loading 

rate of naturally aerobic lagoons shall not exceed the loading rate indicated by the 

NRCS Agricultural Waste Management Field Handbook (AWMFH) or the maximum 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-51 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

loading rate according to state regulatory requirements, whichever is more stringent. As 

discussed above, the maximum aerobic lagoon lading rate for the San Joaquin Valley is 

45 - 55 lb-BOD5/acre-day. According to Table 4-5 (March 2008) of the NRCS AWMFH, 

finishing swine produce approximately 2.1 lb-BOD5/day per 1,000 lb Animal Unit (AU). 

It will be assumed that the average weight of finishing swine is 150 lb (0.15 AU) and that 

100% of the manure will be flushed to the lagoon system. The minimum lagoon surface 

area required for a naturally aerobic lagoon treating manure from 3,000 finishing swine 

in the San Joaquin Valley can be calculated as follows: 

BOD5 loading (lb/day) = 3,000 head x 0.15 AU/head x 2.1 lb-BOD5/AU-day x 1.00 

= 945 lb-BOD5/day 

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum 

loading rate of 55 lb-BOD5/acre-day = 

945 lb-BOD5/day ÷ 55 lb-BOD5/acre-day = 17.2 acres 

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum 

loading rate of 45 lb-BOD5/acre-day = 

945 lb-BOD5/day ÷ 45 lb-BOD5/acre-day = 21.0 acres 

As shown above the minimum surface area required for a naturally aerobic lagoon 

treating manure from 3,000 finishing swine in the San Joaquin Valley would range from 

approximately 17.2 to 21.0 acres. Based on the space requirements alone it is clear 

that this option is cannot reasonably be required and no further analysis is needed. 

Analysis for a Mechanically Aerated Lagoon Treating Manure from 3,000 Finishing 

Swine

As discussed above, the very large space requirements for naturally aerobic lagoons 

cause this option to be infeasible for most confined animal facilities. Mechanically 

aerating a lagoon can achieve some of the benefits of a naturally aerobic lagoon without 

the large space requirements. However, the costs of energy for complete aeration have 

also caused this option to be infeasible. The amount of energy required for aeration is 

based on the amount of volatile solids excreted by animals that must be treated; thus, 

this cost will be directly proportional to the number of animals at a site. The following 

analysis will determine the cost of emission reductions that can be achieved from a 

mechanically aerated lagoon treating manure from 3,000 finishing swine. 

Biological Oxygen Demand (BOD5)

In order to effectively calculate the costs of this control option, the energy requirement 

for complete aeration must be determined. It should be noted that approximately 1.5 to 

2.5 pounds of oxygen is required to digest 1 pound of Biological Oxygen Demand 

(BOD5) with additional oxygen required for conversion of ammonia to nitrate 

(nitrification). It is generally accepted that at least twice the BOD should be provided for 

complete aeration. Additional oxygen would need to be provided for nitrification. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-52 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

The proposed rule specifies that an aerobic lagoon be designed and operated in 

accordance with NRCS Practice Standard Code 359. NRCS Practice Standard Code 

359 requires that mechanically aerated lagoons use aeration equipment that provides a 

minimum of one pound of oxygen for each pound of daily BOD5 loading. As discussed 

above, a lagoon handling flushed manure from 3,000 finishing swine will have a loading 

rate of approximately 945 lb-BOD5/day (429 kg-BOD5/day). 

Energy Requirement a Mechanically Aerated Lagoon Treating Manure from 3,000 

Finishing Swine

As mentioned above, in a UC Davis study on the performance of mechanical aerators 

for wastewater lagoons, measured aeration efficiencies ranged from 0.10 to 0.68 kg of 

oxygen provided per kW-hr of energy utilized. These efficiency tests were performed in 

clean water and lower aeration efficiencies are expected in liquid manure because of 

the significant amount of solids that it contains. The yearly energy requirement 

mechanically aerated lagoon treating flushed manure from 3,000 finishing swine is 

calculated as follows: 

High Efficiency Aerator

429 kg-BOD5/day ÷ (0.68 kg-O2/kW-hr) x (365 day/year) = 230,272 kW-hr/year 

Low Efficiency Aerator

429 kg-BOD5/day ÷ (0.10 kg-O2/kW-hr) x (365 day/year) = 1,565,850 kW-hr/year 

Cost of Electricity for a Mechanically Aerated Lagoon Treating Manure from 3,000 

Finishing Swine:

Based on the reference given above, the cost of electricity used for this analysis will be 

= $0.0999/kW-hr 

The electricity costs for complete aeration are calculated as follows: 

Low Cost Estimate (High Efficiency Aerator)

230,272 kW-hr/year x $0.0999/kW-hr = $23,004/year

High Cost Estimate (Low Efficiency Aerator)

1,565,850 kW-hr/year x $0.0999/kW-hr = $156,428/year 

VOC Emission Reductions from a Mechanically Aerated Lagoon Treating Manure from 

3,000 Finishing Swine:

It will be conservatively assumed that a mechanically aerated lagoon providing 1 lb of 

oxygen for every 1 lb of BOD5 loading will control 90% of the VOC emissions from the 

lagoon/storage pond. However, as noted above, it is generally accepted that the 

oxygen provided should be twice the BOD5 loading rate for complete aeration; 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-53 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

therefore, the actual control from providing 1 lb of oxygen for every 1 lb of BOD5 loading 

is probably closer to 50%. 

The annual VOC Emission Reductions for mechanically aerated lagoon treating the 

manure from 3,000 finishing swine are calculated as follows and shown in the table 

below: 

[Number of Head] x [Lagoon/Storage Pond VOC EF (lb/head-year)] x [Complete 

Aeration Control Efficiency for Lagoon/Storage Pond] 

Table 20 - VOC Reductions for a Mechanically Aerated Lagoon 

Type of Animal # of 

Head x Lagoon EF (lb/head-yr)* x 

Control 

(%) = lb-VOC/yr 

Finishing Swine 3,000 x 0.4 x 90% = 1,080 

* Based on a study by Rumsey, 91% of swine facility VOC emissions are assumed to be from 

housing barns and 9% of VOC emissions are assumed to be from lagoons25

Cost of VOC Emission Reductions

Low Estimate = ($23,004/year)/[(1,080 lb-VOC/year)(1 ton/2000 lb)] 

 = $42,600/ton of VOC reduced

High Estimate = ($156,428/year)/[(1,080 lb-VOC/year)(1 ton/2000 lb)] 

 = $289,681/ton of VOC reduced

As shown above, the electricity cost alone for a mechanically aerated lagoon for swine 

manure would cause the cost of the VOC reductions to be greater than $42,600/ton. 

This cost does not include the additional electricity cost for nitrification that would 

naturally occur as the lagoons were aerated or equipment costs. Even without these 

costs, it is clear that the cost of the VOC emission reductions achieved are far beyond 

BARCT and any applicable RACT requirements.

c. Aerobic Lagoon Treating Liquid Manure from Poultry 

The following analyses are based on the treatment of manure from 400,000 laying hens 

in naturally aerobic lagoons and mechanically aerated lagoons. 

Space Requirement for a Naturally Aerobic Lagoon Treating Manure from 400,000 

Laying Hens

The following brief analysis will demonstrate that the very large land requirements 

needed to treat the manure from poultry facilities subject to this rule in a naturally 

aerobic lagoon would be beyond what could reasonably be required. Therefore, there is 

 

25 Rumsey, I. C., “Characterizing Reduced Sulfur Compounds and Non-Methane Volatile Organic 

Compounds Emissions from a Swine Concentrated Animal Feeding Operation” (2010) – PhD dissertation 

submitted to the Graduate Faculty of North Carolina State University 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-54 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

no need to perform a detailed analysis that would consider all of the additional costs, 

such as the costs of purchasing additional land, constructing and lining the lagoon(s), 

and additional costs for control of mosquito larvae. 

NRCS Practice Standard Code 359 requires that naturally aerobic lagoons be designed 

to have a minimum treatment surface area as determined on the basis of daily BOD5

loading per unit of lagoon surface. The standard specifies that the maximum loading 

rate of naturally aerobic lagoons shall not exceed the loading rate indicated by the 

NRCS Agricultural Waste Management Field Handbook (AWMFH) or the maximum 

loading rate according to state regulatory requirements, whichever is more stringent. As 

discussed above,, the maximum aerobic lagoon lading rate for the San Joaquin Valley 

is 45 - 55 lb-BOD5/acre-day. According to Table 4-5 (March 2008) of the NRCS 

AWMFH, the total manure produced by a laying hens results in 0.011 lb-BOD5/day. 

Assuming that all of the manure will be flushed to the lagoon system, the minimum 

lagoon surface area required for a naturally aerobic lagoon treating manure from 

400,000 laying hens in the San Joaquin Valley can be calculated as follows: 

BOD5 loading (lb/day) = 400,000 birds x 0.011 lb-BOD5/bird-day x 1 = 4,400 lbBOD5/day 

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum 

loading rate of 55 lb-BOD5/acre-day = 

4,400 lb-BOD5/day ÷ 55 lb-BOD5/acre-day = 80.0 acres 

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum 

loading rate of 45 lb-BOD5/acre-day = 

4,400 lb-BOD5/day ÷ 45 lb-BOD5/acre-day = 97.8 acres 

As shown above the minimum surface area required for a naturally aerobic lagoon 

treating manure from 400,000 laying hens in the San Joaquin Valley would range from 

approximately 80.0 to 97.8 acres. Based on the space requirements alone it is clear 

that this option is cannot reasonably be required and no further analysis is needed. 

Analysis for a Mechanically Aerated Lagoon Treating Manure from 400,000 Laying 

Hens

As discussed above, the very large space requirements for naturally aerobic lagoons 

cause this option to be infeasible for most confined animal facilities. Mechanically 

aerating a lagoon can achieve some of the benefits of a naturally aerobic lagoon without 

the large space requirements. However, the costs of energy for complete aeration have 

also caused this option to be infeasible. The amount of energy required for aeration is 

based on the amount of volatile solids excreted by animals that must be treated; thus, 

this cost will be directly proportional to the number of animals at a site. The following 

analysis will determine the cost of emission reductions that can be achieved from a 

mechanically aerated lagoon treating manure from 400,000 laying hens. 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-55 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Biological Oxygen Demand (BOD5)

In order to effectively calculate the costs of this control option, the energy requirement 

for complete aeration must be determined. It should be noted that approximately 1.5 to 

2.5 pounds of oxygen is required to digest 1 pound of Biological Oxygen Demand 

(BOD5) with additional oxygen required for conversion of ammonia to nitrate 

(nitrification). It is generally accepted that at least twice the BOD should be provided for 

complete aeration. Additional oxygen would need to be provided for nitrification. 

The proposed rule specifies that an aerobic lagoon be designed and operated in 

accordance with NRCS Practice Standard Code 359. NRCS Practice Standard Code 

359 requires that mechanically aerated lagoons use aeration equipment that provides a 

minimum of one pound of oxygen for each pound of daily BOD5 loading. As discussed 

above, a lagoon handling flushed manure from 400,000 laying hens will have a loading 

rate of approximately 4,400 lb-BOD5/day (1,996 kg-BOD5/day). 

Energy Requirement a Mechanically Aerated Lagoon Treating Manure from 400,000 

Laying Hens

As mentioned above, in a UC Davis study on the performance of mechanical aerators 

for wastewater lagoons, measured aeration efficiencies ranged from 0.10 to 0.68 kg of 

oxygen provided per kW-hr of energy utilized. These efficiency tests were performed in 

clean water and lower aeration efficiencies are expected in liquid manure because of 

the significant amount of solids that it contains. The yearly energy requirement 

mechanically aerated lagoon treating flushed manure from 400,000 laying hens is 

calculated as follows: 

High Efficiency Aerator

1,996 kg-BOD5/day ÷ (0.68 kg-O2/kW-hr) x (365 day/year) = 1,071,382 kW-hr/year 

Low Efficiency Aerator

1,996 kg-BOD5/day ÷ (0.10 kg-O2/kW-hr) x (365 day/year) = 7,285,400 kW-hr/year 

Cost of Electricity for a Mechanically Aerated Lagoon Treating Manure from 400,000 

Laying Hens

Based on the reference given above, the cost of electricity used for this analysis will be 

= $0.0999/kW-hr 

The electricity costs for complete aeration are calculated as follows: 

Low Cost Estimate (High Efficiency Aerator)

1,071,382 kW-hr/year x $0.0999/kW-hr = $107,031/year

High Cost Estimate (Low Efficiency Aerator)

7,285,400 kW-hr/year x $0.0999/kW-hr = $727,811/year 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-56 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

VOC Emission Reductions from a Mechanically Aerated Lagoon Treating Manure from 

400,000 Laying Hens

It will be conservatively assumed that a mechanically aerated lagoon providing 1 lb of 

oxygen for every 1 lb of BOD5 loading will control 90% of the VOC emissions from the 

lagoon/storage pond. However, as noted above, it is generally accepted that the 

oxygen provided should be twice the BOD5 loading rate for complete aeration; 

therefore, the actual control from providing 1 lb of oxygen for every 1 lb of BOD5 loading 

is probably closer to 50%. 

The annual VOC Emission Reductions for mechanically aerated lagoon treating the 

manure from 400,000 laying hens are calculated as follows and shown in the table 

below: 

[Number of Birds] x [Lagoon/Storage Pond VOC EF (lb/bird-year)] x [Complete Aeration 

Control Efficiency for Lagoon/Storage Pond] 

Table 21 - VOC Reductions for a Mechanically Aerated Lagoon 

Type of Animal # of Birds x Lagoon EF 

(lb/Bird-yr)* x 

Control 

(%) = lb-VOC/yr 

Laying Hens 400,000 x 0.00225 x 90% = 810 

* Based on information for dairy and swine, the lagoon emission factor for poultry is assumed to be 

9% of the total emission factor

Cost of VOC Emission Reductions

Low Estimate = ($107,031/year)/[(810 lb-VOC/year)(1 ton/2000 lb)] 

 = $264,274/ton of VOC reduced

High Estimate = ($727,811/year)/[(810 lb-VOC/year)(1 ton/2000 lb)] 

 = $1,797,064/ton of VOC reduced

As shown above, the electricity cost alone for a mechanically aerated lagoon for poultry 

manure would cause the cost of the VOC reductions to be greater than $264,274/ton. 

This cost does not include the additional electricity cost for nitrification that would 

naturally occur as the lagoons were aerated or equipment costs. Even without these 

costs, it is clear that the cost of the VOC emission reductions achieved are far beyond 

BARCT and any applicable RACT requirements.

E. Covered Lagoon Digester Vented to a Control Device to Treat Liquid 

Manure Produced by Livestock 

The costs associated with treating the liquid manure produced by livestock in a covered 

lagoon digester vented to a control device are analyzed below. This practice is only 

applicable to manure that is handled in liquid form; therefore this cost analysis will 

evaluate this option only for dairy cattle, swine, and layers because these confined 

animal facilities frequently handle manure in liquid form. EPA’s AgSTAR anaerobic 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-57 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

digester database indicates that covered lagoon anaerobic digesters are currently used 

at dairy and swine facilities with a greater number currently used at dairy facilities. The 

database does not list any covered lagoon digesters currently used at poultry or beef 

cattle facilities.26 

 

Description of Control Technology

Covered treatment lagoons are one type of anaerobic digester. As discussed above, an 

anaerobic digester is an enclosed basin or tank that is designed to facilitate the 

decomposition of wastewater by microbes in the absence of oxygen. The process of 

anaerobic decomposition results in the conversion of organic compounds in the 

wastewater into methane (CH4), carbon dioxide (CO2), and water rather than 

intermediate Volatile Organic Compounds (VOCs). Because the gas produced by the 

digester is mostly composed of methane, the main component of natural gas, the gas 

produced in the digester can be cleaned to remove H2S and other impurities and used 

as fuel. 

As stated above, the gas generated in the covered lagoon anaerobic digester can be 

captured and then sent to a suitable combustion device. During combustion, gaseous 

hydrocarbons are oxidized to form CO2 and water. Although the control efficiency of the 

gas captured from the primary lagoon is expected to be very high, the overall control 

efficiency is expected to be less since VOCs will also be emitted from the storage pond 

and as fugitive emissions. For this analysis, the overall control efficiency is assumed to 

be 80% of the emissions that would have been emitted from the lagoon system. 

a. Covered Lagoon Digester for Liquid Manure from Dairy Cows 

The costs associated with treating the manure excreted by milk cows in a covered 

lagoon digester vented to a control device are analyzed below. Because it may be 

possible to generate power from the system to offset some of the costs associated with 

installation, this potential benefit is included in the analysis below. The following 

analysis is based on the treatment of manure from 1,000 milk cows in a covered lagoon 

anaerobic digester with power generation. 

Capital Cost for Installation of a Covered Lagoon Digester for Dairy Cows

The capital cost estimates for installation of a covered lagoon digester are based on 

information from the United States EPA AgSTAR publication “Anaerobic Digestion Capital 

Costs for Dairy Farms” (May 2010) and the California Energy Commission (CEC) Public 

Interest Energy Research (PIER) Program Dairy Methane Digester System Program 

Evaluation Report (Feb 2009). The formula in the AgSTAR publication results in a 

capitol cost of $1,032 per cow for a covered lagoon anaerobic digester treating manure 

from 1,000 cows. This estimate excludes costs of solids separation after digestion, 

 

26 US EPA AgSTAR Program Guide to Anaerobic Digesters – Anaerobic Digester Database (updated 

April 2010), http://www.epa.gov/agstar/operational.html 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

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Revised Proposed Amendments to Rule 4570 

hydrogen sulfide removal, and utility charges including line upgrades and 

interconnection costs and fees. Based on information from installations in California, 

the CEC PIER Dairy Methane Digester Program Evaluation Report gives an average 

cost of $585 per cow for installation of covered lagoon anaerobic digesters (see Table 9 

- Total Project Costs and Cost per Cow and per kW). Therefore, for purposes of this 

analysis the capital cost for installation of a covered lagoon digester system for 1,000 

cows will be assumed to be between $585/cow and $1,032/cow. The capital cost 

estimates of a covered lagoon digester treating the manure of 1,000 milk cows is 

calculated as follows: 

Low capital cost estimate: $585/cow x 1,000 cows = $585,000 

High capital cost estimate: $1,032/cow x 1,000 cows = $1,032,000 

The annualized capital cost estimates will be calculated below. The capital cost for the 

installation of the covered lagoon digester will be spread over the expected life of the 

system using the capital recovery equation. The expected life of the entire system will 

be estimated at 10 years though the cover may require replacement during this period. 

A 10% interest rate is assumed in the equation and the assumption will be made that 

the equipment has no salvage value at the end of the ten-year cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Low Annual Capital Cost Estimate = [$585,000 x 0.1(1.1)10]/[(1.1)10-1] = $95,206/year

High Annual Capital Cost Estimate = [$1,032,000 x 0.1(1.1)10]/[(1.1)10-1] =

$167,953/year 

Potential Production of Electricity from a Covered Lagoon Digester Treating Manure 

from 1,000 Milk Cows:

It may be possible to offset some of the installation costs of a covered lagoon anaerobic 

digester with revenue from generation of electricity. Based on the information given in 

the CEC PIER Dairy Methane Digester Program Evaluation Report, Table 7 – Actual 

Generation per Cow Comparisons, California dairies that used a covered lagoon 

digester to produce electricity generated between 429.1 and 1,031.8 kW-hr/yr per 

lactating cow with a overall per facility average generation rate of 670.3 kW-hr/yr per 

lactating cow. This average annual generation rate is actually higher than all the 

facilities included in the average except one that had a very high generation rate. In 

addition, this average may overestimate the per-cow generation potential because the 

contributions of support stock to the digesters were not accounted for. However, for 

more conservative calculations, this average will be used to calculate the potential 

annual savings in electricity costs. The potential production of electricity from a covered 

lagoon digester treating manure from 1,000 milk cows is calculated as follows: 

Electrical Production: 670.3 kW-hr/(milk cow-yr) x 1,000 milk cows = 670,300 kWhr/yr 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-59 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Potential Cost Savings from Production of Electricity from a Covered Lagoon Digester

Treating Manure from 1,000 Milk Cows:

Based on the reference given above, the value of electricity used for this analysis will be 

= $0.0999/kW-hr 

The potential annual cost savings from electricity generation from a covered lagoon 

digester treating manure from 1,000 milk cows is calculated as follows: 

Potential Annual Cost Savings from Electrical Production: 

670,300 kW-hr/yr x $0.0999/kW-hr = $66,963/yr 

Annualized Capital Cost for a Covered Lagoon Digester Treating Manure from 1,000

Milk Cows minus Potential Savings from Generation of Electricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation 

= $95,206/yr - $66,963/yr = $28,243/year 

High Annual Capital Cost Estimate minus Savings from Potential Generation 

= $167,953/yr - $66,963/yr = $100,990/year 

VOC Emission Reductions from a Covered Lagoon Anaerobic Digester Treating Manure 

from 1,000 Milk Cows:

The annual VOC Emission Reductions for covered lagoon anaerobic digester treating 

the manure from 1,000 milk cows are calculated as follows and shown in the table 

below: 

[Number of cows] x [Lagoon/Storage Pond VOC EF (lb/cow-year)] x [Covered Lagoon 

Digester Control Efficiency for Lagoon/Storage Pond] 

Table 22 - VOC Reductions for a Covered Lagoon Vented to Control Device 

Type of Cow # of 

cows 

x Lagoon EF 

(lb/cow-yr) x 

Control 

(%) = lb-VOC/yr 

Milk Cow (freestall) 1,000 x 1.3 x 80% = 1,040 

Cost of VOC Emission Reductions

Low Estimate = ($28,243/year)/[(1,040 lb-VOC/year)(1 ton/2000 lb)] 

 = $54,313/ton of VOC reduced

High Estimate = ($167,953/year)/[(1,040 lb-VOC/year)(1 ton/2000 lb)] 

 = $322,987/ton of VOC reduced

As shown above, the capital cost alone for a covered lagoon digester for a dairy would 

cause the cost of the VOC reductions to be greater than $54,313/ton. This cost 

includes the potential revenue generated by electrical production but does not include 

the additional maintenance required for the system. Even without these costs, it is clear 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-60 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

that the cost of the VOC emission reductions achieved are far beyond BARCT and any 

applicable RACT requirements. This analysis did not consider the additional pollution 

that would be generated by any combustion equipment that would utilize the gas, which 

may offset any reductions in VOCs. In general, this option would not likely be 

considered economically feasible for any facility without the project receiving substantial 

subsidies to offset the extremely high costs of installation. 

b. Covered Lagoon Digester for Swine Manure 

The costs associated with treating the manure excreted by finishing swine in a covered 

lagoon digester vented to a control device are analyzed below. Because it may be 

possible to generate power from the system to offset some of the costs associated with 

installation, this potential benefit is included in the analysis below. The following 

analysis is based on the treatment of manure from 5,000 finishing swine in a covered 

lagoon anaerobic digester with power generation. 

Capital Cost for Installation of a Covered Lagoon Digester for Swine

On an animal weight basis, the capital cost estimates for installation of a covered lagoon 

digester for finishing swine are assumed to be the same as the costs for installation of a 

covered lagoon digester at a dairy. Based on the information given above, the capital cost 

of installation of a covered lagoon digester at a dairy is between $585 and $1,032 per cow. 

A typical milk cow weighs approximately 1,400 lb and the average weight of finishing 

swine is assumed to be 150 lb. The estimated capital cost of a covered lagoon digester 

for finishing swine is estimated by adjusting by weight as follows: 

Low capital cost estimate: $585/cow x 150 lb/head/(1,400 lb/cow) = $63/head 

High capital cost estimate: $1,032/cow x 150 lb/head/(1,400 lb/cow) = $111/head 

The estimated capital cost of a covered lagoon digester treating the liquid manure from 

5,000 finishing swine is calculated as follows: 

Low capital cost estimate: 5,000 head x $63/head = $315,000 

High capital cost estimate: 5,000 head x $111/head = $555,000 

The annualized capital cost estimates will be calculated below. The capital cost for the 

installation of the covered lagoon digester will be spread over the expected life of the 

system using the capital recovery equation. The expected life of the entire system will 

be estimated at 10 years though the cover may require replacement during this period. 

A 10% interest rate is assumed in the equation and the assumption will be made that 

the equipment has no salvage value at the end of the ten-year cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Low Annual Capital Cost Estimate = [$315,000 x 0.1(1.1)10]/[(1.1)10-1] = $51,265/year

High Annual Capital Cost Estimate = [$555,000 x 0.1(1.1)10]/[(1.1)10-1] = $90,324/year
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-61 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Potential Production of Electricity from a Covered Lagoon Digester Treating Manure 

from 5,000 Finishing Swine:

It may be possible to offset some of the installation costs of a covered lagoon anaerobic 

digester with revenue from generation of electricity. Production of electricity from 

digester gas from swine manure generally requires a very large facility to be 

economically attractive; therefore it has been more common to flare the gas from 

covered lagoons at swine facilities for abatement of odors or to use the gas in a boiler or 

furnace. Because there is limited information available regarding production of 

electricity from digester gas from swine manure, the potential for production of electricity 

will be estimated based on the information given above for production of electricity from 

covered lagoon digesters at dairy facilities. It will be assumed that the potential for 

production of digester gas and electricity from dairy cows and swine will be proportional 

to the amount of volatile solids excreted in the manure. According to the United States 

Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) 

Agricultural Waste Management Field Handbook (AWMFH), Chapter 4 - Agricultural 

Waste Characteristics27 (March 2008), a lactating dairy cow excretes an average of 

approximately 17 lb/day of volatile solids and finishing swine excrete approximately 5.4 

lb/day of volatile solids per 1,000-lb AU. Based on the information given above, a 

covered lagoon anaerobic digester at a dairy is estimated to produce 670.3 kW-hr per 

milk cow per year. Assuming that the amount of electricity produced is proportional to 

the amount of volatile solids sent to the covered lagoon, the potential production of 

electricity from a covered lagoon anaerobic digester at a finishing swine facility is 

estimated as follows: 

(0.15 AU/swine x 5.4 lb VS/AU)/(17 lb-VS/milk cow) x 670.3 kW-hr/(milk cow-yr) 

= 31.9 kW-hr/(swine-yr) 

The potential production of electricity from a covered lagoon digester treating manure from 

5,000 finishing swine is calculated as follows: 

Electrical Production: 31.9 kW-hr/(swine-yr) x 5,000 swine = 159,500 kW-hr/yr 

Potential Cost Savings from Production of Electricity from a Covered Lagoon Digester

Treating Manure from 5,000 Swine:

Based on the reference given above, the value of electricity used for this analysis 

will be = $0.0999/kW-hr 

The potential annual cost savings from electricity generation from a covered lagoon 

digester treating manure from 5,000 swine is calculated as follows: 

159,500 kW-hr/yr x $0.0999/kW-hr = $15,934/yr 

 

27 United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) 

Agricultural Waste Management Field Handbook (AWMFH), 

http://policy.nrcs.usda.gov/viewerFS.aspx?hid=21430 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-62 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

Annualized Capital Cost for a Covered Lagoon Digester Treating Manure from 5,000 

Swine minus Potential Savings from Generation of Electricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation 

= $51,265/yr - $15,934/yr = $35,331/year 

High Annual Capital Cost Estimate minus Savings from Potential Generation 

= $90,324/yr - $15,934/yr = $74,390/year 

VOC Emission Reductions from a Covered Lagoon Anaerobic Digester Treating Manure 

from 5,000 Finishing Swine:

The annual VOC Emission Reductions for covered lagoon anaerobic digester treating 

the manure from 5,000 swine are calculated as follows and shown in the table below: 

[Number of swine] x [Lagoon/Storage Pond VOC EF (lb/cow-year)] x [Covered Lagoon 

Digester Control Efficiency for Lagoon/Storage Pond] 

Table 23 - VOC Reductions for a Covered Lagoon Vented to Control Device 

Animal # of 

Head x Lagoon EF (lb/head-yr)* x 

Control 

(%) = lb-VOC/yr 

Finishing Swine 5,000 x 0.4 x 80% = 1,600 

* Based on a study by Rumsey, 91% of swine facility VOC emissions are assumed to be from 

housing barns and 9% of VOC emissions are assumed to be from lagoons28

Cost of VOC Emission Reductions

Low Estimate = ($35,331/year)/[(1,600 lb-VOC/year)(1 ton/2000 lb)] 

 = $44,164/ton of VOC reduced

High Estimate = ($74,390/year)/[(1,600 lb-VOC/year)(1 ton/2000 lb)] 

 = $92,988/ton of VOC reduced

As shown above, the capital cost alone for a covered lagoon digester for swine would 

cause the cost of the VOC reductions to be greater than $44,164/ton. This cost 

includes the potential revenue generated by electrical production but does not include 

the additional maintenance required for the system. Even without these costs, it is clear 

that the cost of the VOC emission reductions achieved are far beyond BARCT and any 

applicable RACT requirements. This analysis did not consider the additional pollution 

that would be generated by any combustion equipment that would utilize the gas, which 

may offset any reductions in VOCs. In general, this option would not likely be 

considered economically feasible for any facility without the project receiving substantial 

subsidies to offset the extremely high costs of installation. 

 

28 Rumsey, I. C., “Characterizing Reduced Sulfur Compounds and Non-Methane Volatile Organic 

Compounds Emissions from a Swine Concentrated Animal Feeding Operation” (2010) – PhD dissertation 

submitted to the Graduate Faculty of North Carolina State University 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-63 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

c. Covered Lagoon Digester for Poultry Manure 

Although treating the manure excreted by laying hens in a covered lagoon digester 

appears to be very uncommon, the costs associated with treating the manure excreted 

by laying hens in a covered lagoon digester are analyzed below. Because it may be 

possible to generate power from the system to offset some of the costs associated with 

installation, this potential benefit is included in the analysis below. The following 

analysis is based on the treatment of manure from 500,000 laying hens in a covered 

lagoon anaerobic digester with power generation. 

Capital Cost for Installation of a Covered Lagoon Digester for Poultry

On an animal weight basis, the capital cost estimates for installation of a covered lagoon 

digester for poultry are assumed to be the same as the costs for installation of a covered 

lagoon digester at a dairy. Based on the information given above, the capital cost of 

installation of a covered lagoon digester at a dairy is between $585 and $1,032 per cow. 

A typical milk cow weighs approximately 1,400 lb and the average weight of a laying hen 

is assumed to be 4 lb. The estimated capital cost of a covered lagoon digester for poultry 

is estimated by adjusting by weight as follows: 

Low capital cost estimate: $585/cow x 4 lb/bird/(1,400 lb/cow) = $1.67/bird 

High capital cost estimate: $1,032/cow x 4 lb/bird/(1,400 lb/cow) = $2.95/bird 

The estimated capital cost of a covered lagoon digester treating the liquid manure from 

500,000 laying hens is calculated as follows: 

Low capital cost estimate: 500,000 birds x $1.67/bird = $835,000 

High capital cost estimate: 500,000 birds x $2.95/bird = $1,475,000 

The annualized capital cost estimates will be calculated below. The capital cost for the 

installation of the covered lagoon digester will be spread over the expected life of the 

system using the capital recovery equation. The expected life of the entire system will 

be estimated at 10 years though the cover may require replacement during this period. 

A 10% interest rate is assumed in the equation and the assumption will be made that 

the equipment has no salvage value at the end of the ten-year cycle. 

A = [P x I(I+1)n]/[(I+1)n-1] 

Low Annual Capital Cost Estimate = [$835,000 x 0.1(1.1)10]/[(1.1)10-1] = $135,892/year

High Annual Capital Cost Estimate = [$1,475,000 x 0.1(1.1)10]/[(1.1)10-1] = $240,049/year 

Potential Production of Electricity from a Covered Lagoon Digester Treating Manure 

from 500,000 Laying Hens:

It may be possible to offset some of the installation costs of a covered lagoon anaerobic 

digester with revenue from generation of electricity. Only a very small number of 
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Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-64 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

digesters have been installed at poultry facilities and there was no information available 

on any covered lagoon digesters at poultry facilities.29 Because there is limited 

information available regarding production of electricity from digester gas from poultry 

manure, the potential for production of electricity will be estimated based on the 

information given above for production of electricity from covered lagoon digesters at 

dairy facilities. It will be assumed that the potential for production of digester gas and 

electricity from dairy cows and poultry will be proportional to the amount of volatile 

solids excreted in the manure. According to the USDA NRCS Agricultural Waste 

Management Field Handbook (AWMFH), Chapter 4 - Agricultural Waste Characteristics

(March 2008), a lactating dairy cow excretes an average of approximately 17 lb/day of 

volatile solids and a laying hen excretes approximately 0.036 lb/day of volatile solids. 

Based on the information given above, a covered lagoon anaerobic digester at a dairy is 

estimated to produce 670.3 kW-hr per milk cow per year. Assuming that the amount of 

electricity produced is proportional to the amount of volatile solids sent to the covered 

lagoon, the potential production of electricity from a covered lagoon anaerobic digester at 

a poultry facility is estimated as follows: 

(0.036 lb-VS/bird)/(17 lb-VS/milk cow) x 670.3 kW-hr/(milk cow-yr) = 1.42 kWhr/(bird-yr) 

The potential production of electricity from a covered lagoon digester treating manure from 

500,000 laying hens is calculated as follows: 

Electrical Production: 1.42 kW-hr/(bird-yr) x 500,000 birds = 710,000 kW-hr/yr 

Potential Cost Savings from Production of Electricity from a Covered Lagoon Digester

Treating Manure from 500,000 Laying Hens:

Based on the reference given above, the value of electricity used for this analysis will be 

= $0.0999/kW-hr 

The potential annual cost savings from electricity generation from a covered lagoon 

digester treating manure from 500,000 laying hens is calculated as follows: 

710,000 kW-hr/yr x $0.0999/kW-hr = $70,929/yr 

Annualized Capital Cost for a Covered Lagoon Digester Treating Manure from 500,000 

Birds minus Potential Savings from Generation of Electricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation 

= $135,892/yr - $70,929/yr = $64,963/year 

High Annual Capital Cost Estimate minus Savings from Potential Generation 

= $240,049/yr - $70,929/yr = $169,120/year 

 

29 The US EPA AgSTAR Program Guide to Anaerobic Digesters – Anaerobic Digester Database (updated 

April 2010) lists only three poultry digesters, http://www.epa.gov/agstar/operational.html 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-65 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

VOC Emission Reductions from a Covered Lagoon Anaerobic Digester Treating Manure 

from 500,000 Birds:

The annual VOC Emission Reductions for covered lagoon anaerobic digester treating 

the manure from 500,000 birds are calculated as follows and shown in the table below: 

[Number of Birds] x [Lagoon/Storage Pond VOC EF (lb/cow-year)] x [Covered Lagoon 

Digester Control Efficiency for Lagoon/Storage Pond] 

Table 24 - VOC Reductions for a Covered Lagoon Vented to Control Device 

Animal # of Birds x Lagoon EF 

(lb/Bird-yr)* x 

Control 

(%) = lb-VOC/yr 

Laying Hens 500,000 x 0.00225 x 80% = 900 

* Based on information for dairy and swine, the lagoon emission factor for poultry is assumed to be 

9% of the total emission factor

Cost of VOC Emission Reductions

Low Estimate = ($64,963/year)/[(900 lb-VOC/year)(1 ton/2000 lb)] 

 = $144,362/ton of VOC reduced

High Estimate = ($169,120/year)/[(900 lb-VOC/year)(1 ton/2000 lb)] 

 = $375,822/ton of VOC reduced

As shown above, the capital cost alone for a covered lagoon digester for poultry would 

cause the cost of the VOC reductions to be greater than $144,362/ton. This cost 

includes the potential revenue generated by electrical production but does not include 

the additional maintenance required for the system. Even without these costs, it is clear 

that the cost of the VOC emission reductions achieved are far beyond BARCT and any 

applicable RACT requirements. This analysis did not consider the additional pollution 

that would be generated by any combustion equipment that would utilize the gas, which 

may offset any reductions in VOCs. In general, this option would not likely be 

considered economically feasible for any facility without the project receiving substantial 

subsidies to offset the extremely high costs of installation. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix E: Class Two Measures Analysis for Rule 4570 October 21, 2010 

 E-66 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

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