Large CAF definition workshop March 2
The California Air Resources Board has released its initial ideas for defining a “large” dairy, a key step in deciding which dairies will be required to obtain air pollution permits in the future. CARB plans a workshop Wednesday, March 2 to hear comments, the latest step in implementation of Senate Bill 700 (Florez, 2003), which subjects agriculture and livestock operations to increased air quality regulation.
Under one option, CARB would define a Large Confined
Animal Facility (LCAF) based on the number of animals on the site. CARB proposes
that a large dairy be defined as either containing 700 milking cows, or 2,000
milking cows. The proposal potentially would allow other animals on the
operation to be counted as fractions of milking cows – that is, heifers and
calves would be counted as less than one cow, because they produce less manure
and air emissions. Unfortunately, this option doesn’t consider actual emissions
from the dairies. Instead, the 700 number is extracted from a previously
published federal water quality rule, while the 2,000 number appears to be
The second option would base the “large” definition on actual emissions. This would force regulators to base their decisions on science-based emission factors instead of arbitrarily deciding what is and is not a large operation. Under this proposal, a “large” dairy would be defined as any facility producing more than 12.5 tons annually of smog-forming emissions known as reactive organic gases (ROG). Recent research has shown that the existing ROG emissions estimates are incorrect, and may well show that the actual emissions are smaller than previously estimated. The issue is critical to all California dairy operators, because anyone defined as “large” will be required to obtain a permit and to adopt technologies and/or management practices to reduce emissions. WUD will continue to advocate that the “large CAF” definition be based on solid science. For a detailed copy of the current CARB proposal, go to www.arb.ca.gov/ag/caf/large_caf_def_options_2_18_05.pdf
The workshop will be held at the San Joaquin Valley Air Pollution Control District office in Fresno from 1:30 p.m. to 4:30 p.m. It will be teleconferenced to the Modesto and Bakersfield offices, as well as to the South Coast Air Quality Management District. The workshop is part of the process to implement provisions of air quality legislation known as SB 700.