The agriculture industry is faced with regulations from a number of different government agencies. These regulations are put in place to protect the general public, as well as the producers themselves. However, there comes a time when some of those regulations become detrimental to producers. The Environmental Protection Agency is currently proposing a particulate matter standard that is twice as stringent as the current standard in their review of the National Ambient Air Quality Standards.
The EPA staff review states that the administrator would be justified in either retaining the current PM standard of 150 micrograms per cubic meter, or in revising it to make it more stringent. EPA’s staff suggests considering a PM of 65-85 micrograms per cubic meter, which is essentially twice as severe as the current standard. Such a level would require the designation of many more nonattainment areas than currently exist, and would be very difficult, if not impossible, for many cattle operations to meet.
The NAAQS is a health-based standard, meaning that in order to regulate pollutants in the air, scientific studies must show that the pollutant causes adverse health effects. Quite the opposite, if scientific studies do not show that a pollutant causes adverse health effects, it is not supposed to be regulated under the NAAQS. With this in mind, the EPA chose to regulate all particles that fall within the fine PM size range, including dust; instead of appropriately basing its regulation on particle composition. That decision, made in 2007, resulted in dust being treated as if it causes the same adverse health effects as cigarette smoke.
Agriculture producers already manage dust with proactive dust control measures and best management practices. Every day producers employ environmentally-friendly practices including windbreaks, watering down dirt roads and using sprinklers to reduce dirt in cattle pens. Many of these activities are mandated and/or monitored by clean air permits/committees. If the more stringent regulations are put into place; it will make it virtually impossible for not only farmers and ranchers, but many U.S. industries, to comply with the new standard.
Twenty-one senators submitted a letter to the EPA stating, “If approved, this would establish the most stringent and unparalleled regulation of dust in our nation’s history.” It further states, “We respect efforts for a clean and healthy environment, but not at the expense of common sense. These identified levels will be extremely burdensome for farmers and livestock producers to attain. Whether it is livestock kicking up dust, soybeans being combined on a dry day in the fall, or driving a car down the gravel road, dust is a naturally-occurring event.”
