STATEMENT OF THE AMERICAN FARM BUREAU FEDERATION
TO THE CLEAN AIR, WETLANDS, PRIVATE PROPERTY AND NUCLEAR SAFETY SUBCOMMITTEE
SENATE ENVIRONMENT & PUBLIC WORKS COMMITTEE
REGARDING AIR QUALITY STANDARDS
Presented by Adam Sharp
Assistant Director Governmental Relations
American Farm Bureau Federation
October 22, 1997

Thank you, Mr. Chairman, for the opportunity to provide testimony for this important hearing on air quality. I am Adam Sharp, Assistant Director of Governmental Relations for the American Farm Bureau Federation, here in Washington, D.C. I also am a partner in my family's farm in southeastern Ohio. Along with my three brothers, father and grandfather, we operate a dairy farm and a diversified crop farm. I am a member of the Virginia Farm Bureau Federation and today I am representing the American Farm Bureau Federation, the nation's largest general farm organization with more than 4.7 million member families. I am pleased to have the opportunity to discuss with you today the impacts of new air standard on the agricultural community. My comments focus primarily on the Environmental Protection Agency's decision to revise the National Ambient Air Quality Standard (NAAQS) for particulate matter. Farm Bureau supports Senate Bill 1084 for many reasons. but foremost because it would allow the necessary time for the agriculture community and EPA to gain a mote accurate understanding of agriculture emissions, how much we emit, and to what extent the air quality standards will impact our industry My comments focus primarily on the new PM-2.5 standard.

As a preface to my comments, I think that it would be appropriate to share with you a portion of Farm Bureau's policy on air quality chat was adopted by delegates to our annual meeting. It clearly outlines the position of America's farmers and rancher.' regarding the importance of clean air. It reads in part:

"We support a healthy environment." "We support government policies that:

Are based on sound scientific evidence; provide incentives to industries seeking to become more energy efficient or to reduce emissions of identifiable atmospheric pollutants; sect cooperation of organizations and governments, foreign and domestic, to develop better understanding and research on the implications of atmospheric pollution and the means of preventing it."

The evidence is quite strong that conservation has been a priority for farmers and ranchers for many years. There has been and continues to be a tremendous amount of conservation activity on farms and ranches across the country. These activities include such things as protecting wildlife habitat, creating wetlands, grassed waterways and field buffer strips. We also use conservation tillage techniques, cover crops and planting trees and vegetation for wind breaks. All these activities reduce wind erosion of the soil. which in turn, provides cleaner air. The Conservation Reserve Program alone will idle up to 36.4 million acres across the country that provides vegetation that stabilizes soil and prevents wind blown dust. Wind erosion on 84 percent of the nation's rangeland, 86 percent of the cropland, and virtually all of the pasture land is now less than the tolerable soil loss rate -- meaning, the rate at which soil erosion can occur without surpassing the natural rate of soil regeneration (which is 2-12 tones per acre per year). And soil lost to wind erosion continues to decrease as farmers expand these extremely environmentally beneficial practices. Farmers are cleaning the air and should get credit for those activities.

However, agriculture is concerned because EPA lacks actual measurements of what agriculture emits in the form of fine particulate. One estimate is that 34.3 percent of primary fine particulate matter can be attributed to agriculture and forestry. Another suggests as low as 5 percent of primary fine particulate. However, that figure does not take into account diesel emissions. fertilizer and chemical sources, unpaved roads, organic and ammonia sources and many others.

EPA is finally acknowledging what we have been telling them: Agriculture is not a major emitter of this pollutant However, nothing has been done to date to correct faulty documentation that overestimates agricultural sources, or solidify Administrator Browners' promise that agriculture will not be impacted. The administrator's promises have done little for our concerns because State decide who will be regulated, not her.

Regarding these questionable estimates, I quote Dr. Calvin Parnell, a professor of Agricultural Engineering at Texas A&M University and a member of the U.S. Department of Agriculture's Task Force on Air Quality. He says, and we agree that:

"The data used to develop this inventory was based on erroneous emission factors published by CPA for cattle feed yards, feed mills, grain elevators and dust from farmers' field operations."

Those comments were made last spring in a hearing held by a subcommittee of the House Agriculture Committee, Furthermore, I quote the Honorable Larry Combest, Chairman of the House Agriculture Subcommittee on Forestry Resource Conservation, and Research, from that same hearing. He says, and we agree, that:

"The science employed in developing this rule is not up to par, and I'm concerned that farmers could bear the brunt of a bad policy based on equally bad science, We don't have the research yet to know whether we can actually attain theme standards, how much it will cost the agriculture industry and the consuming public, and bow much agriculture activity actually contribute to air pollution problems."

We share these same concerns. We also commend and extend the comments raised by the USDA, the USDA Task Force on Air Quality and the Small Business Administration in regards to economic impacts of this standard on farms and ranches.

CALIFORNIA SITUATION

Today, however, I want to focus on the actual present situation California agriculture is dealing with in regards to the present PM-I 0 Non-Attainment Area for central and southern California. as determined by the 1990 Amendments to the Clean Air Act. Under this status, a major potion of California's agriculture has been faced with a number of challenges which, in many cases, are yet to be resolved. Agriculture in others areas of the country may face the same situations if a new PM standard is imposed.

The money, time and resources California agriculture has spent attempting to meet the PM-10 ambient air quality standard has given Farm Bureau plenty of reasons to believe that we cannot jump immediately into a new air quality standard of which we know so little about. It is an absolute necessity to allow science surrounding PM-2.5 to develop so that intelligent, reasonable and justifiable decisions can be made.

Let me expand on one air district's experiences in dealing with the present PM-10 standard. These are examples of situations agriculture has faced in the San Joaquin Valley Unified Air Pollution Control District.

EXAMPLE 1: The emission inventory for agricultural tillage operations was the focus of the initial discussions with the air district. There are two major problems identified in this inventory. First, the actual number of passes the equipment makes per acre, and second, the PM-10 emission produced from each type of operation such as discing, ripping or furrowing. This problem was due to the fact that information, published by the EPA, indicated that alfalfa was disced 8 times per year, rice 13 times per year and rangeland twice per year. This greatly overestimated the emissions and made agriculture the prime target. First, farmers disc and seed alfalfa maybe only once every 3 or more years, not 8 per year, and farmers don't even disc rice or rangeland at all, especially 13 times and twice per year respectively.

Some of the control measures suggested for agriculture operations included: sprinkler irrigation on fields prior to planting; water tanks mounted on tractors and water sprays on the back of discing equipment (without thing into account that water is at a premium in California), and the use of shaking equipment to shake trucks and farm implements prior to exiting a field or unpaved road onto a paved road (this would supposedly eliminate the carry-out of mud or dirt, which would later be entrained into the atmosphere by cars or trucks on paved roads). These irrational and impractical controls would have done little if nothing to clean the air and would have been extremely costly for California agriculture, had they not been corrected.

Just by updating the inventory with current acreage information for each crop and correcting the number of passes per acre for tillage equipment, the agricultural PM-10 emission inventory for tillage operations was reduced 30 percent.

EXAMPLE 2: At one point it was discussed that farms should be permitted by their local air districts. In the San Joaquin Valley alone, it was speculated that there would be over 31,000 permits for farms written. Each silage pile, unpaved road and equipment storage yard, to name a few, would have been permitted. The District estimated that they would need 70 additional permitting engineers to process air quality permits just for farms (local stationary source permit, and also a Federal Operating permit).

EXAMPLE 3: As, I indicated, there has been information used by the air districts that identifies agriculture as a primary source of PM-10 emissions. For the past 5 years, California's agriculture community has fought to address the deficiencies in those inventories. One example is windblown dust emissions from agricultural lands. In the original inventory, it was assumed that all farming in California was "dryland" farmed. It assumed that the land was not irrigated, and that there was no vegetation cover, or cover canopy, from the crops. Once irrigation and vegetation cover was put into the wind erosion equations, the wind erosion PM-10 emission inventory was reduced an incredible 80 percent from 410 tons per day of PM-10, to 58 tons per day of PM-10.

EXAMPLE 4: Probably the most blatant example of an inaccurate inventory, which would have cost the agricultural industry thousands of dollars, was the initial emission inventory for combustion engines used to drive irrigation pumps. The original inventory estimated nitrogen oxide (NOX) emissions (a precursor of PM) at 626 tons per day from all of the diesel engine pumps in the San Joaquin Valley. This would be the highest emissions category for NOX emissions in the San Joaquin Valley, exceeding all the mobile sources including all cars and trucks, which together only emit 353 tons per day. Driven by agricultural inquiries a new study was commissioned that was based on actual interviews with 360 farmers. The new study determined that the NOX emission for these pumps is only 32 tons per day.

We have only begun to address agriculture's problems with PM-I 0 measurements. Many of which are still unaddressed and uncorrected. And, other PM-I 0 issues are still arising. For example, EPA is also looking at oxides of nitrogen (NOX) and ammonia (NH3) from soils as contributors to ambient levels of PM-10. This could mean farmers will also have to address the application of fertilizers and pesticides as an air quality concern, not to mention livestock. Yet, recent studies performed in the Valley indicate that there is very little NOX or NH3 emissions from the soil. Questions about how much particulate matter is released into the air through natural occurrences, such as high wind or volcanoes also remain to be addressed.

Considering all these discrepancies, it is unbelievable the we are now again faced with the same problems, only this time with smaller particulate matter. Based on the 1994 Emissions Inventory for the National Particulate Matter Study, fugitive dust emissions from agriculture have been listed as the third largest source of PM-2.5 nationwide, falling behind paved and unpaved roads. This is hard to believe, since there has never been any actual PM-2.5 emission data taken on agricultural tillage equipment using EPA approved PM-2.5 samplers. All of these examples only emphasizes the necessity to fully study PM-2.5 before deadlines are set and rules are developed.

CALIFORNIA STUDY

In attempting to resolve some of the previously mentioned issues, it became necessary to conduct a multi-year, multi-faceted air quality study. Such a study was developed and is now underway in California. This study, known as the California Regional Particulate Matter Air Quality Study (CRPMAQS), will address all areas of PM-10 and PM-2.5 issues. This includes emissions determinations and quantifications, data analyses, demonstration studies, ambient air quality measurements and model development. USDA is playing a major role in this study by helping to fund emissions studies for agricultural activities and operations. Once completed, it will be the source by which decisions in regards to particulate matter will be made in California, and will serve to aid other areas in the nation and the world in their particulate matter decision-making process.

This comprehensive study, however, will not be completed for roughly five years and is not all inclusive for agricultural sources. 5.1084 would give agriculture the needed time to attain this important agriculture PM-2.5 emissions data I want to emphasize that this study is the first comprehensive study that actually measures, instead of estimating, agriculture's PM-2.5 emissions. In order to avoid the mistakes made for PM-10, this study and others like it must be completed before implementation activities, attainment deadlines and regulations begin for yet a new PM standard.

CONCLUSION

In conclusion, I want to reiterate that much work is yet to even begin in regards to agriculture industry emissions which should be finished before setting a new standard for particulate matter. We must develop an accurate measurement method for PM-2.5 in order to determine and quantify the significant sources of PM-2.5 and we must complete the necessary research to understand the true nature of PM-2.5 and what contributes to its formation so as not to make the same mistakes that we are making with agricultural PM-10 emissions.

The present approach will only serve to put American agriculture at a competitive disadvantage with other countries and put agricultural producers out of work. Because U.S. agricultural commodity prices are tied to world prices, a farmer cannot simply "pass on" the cost of doing business to the consumer. In other words, we are "price takers and not a price makers." Therefore, any increase in operational costs of farming is significant and must be based on accurate information that justifies the expenditures.

Agriculture will also see a tremendous amount of indirect impact from the new standards. Targeted industries such as the utilities, fuel, transportation, chemical, equipment and many more will pass costs on to their users. One of which is agriculture. In a study by AUS Consultants to be released soon, net cash income for all farmers is projected to fall by 10 percent or $5 billion annually over the first 6 years of implementation of these standards.

We also want to be careful in not tipping the balance of regulation in this country too far, and force our grocers to fill market orders with food purchased from other countries that do not always meet the same safeguards and health standards as U.S. produced commodities.

The agriculture community enjoys breathing clean air as much as anybody, yet doesn't want to waste money on control measures that have little or no effect on cleaning up the air of this nation.

Finally, the USDA must maintain a strong presence as discussions continue on these new standards. The USDA, the Small Business Administration and the USDA Agricultural Air Quality Task Force and this committee must continue to raise and demand that the concerns of America's farmers and ranchers are addressed by the EFA in order to ensure a continued safe, abundant, healthy and affordable U.S. food supply.

I end on a note of caution as expressed by Paul Johnson, Chief of the Natural Resources Conservation Service of the USDA, who remarked at last spring's hearing that:

"When local air quality administrators make decisions about which pollution control programs to implement they will consider factors such as the percentage of total pollution in the airshed that is caused by a specific activity or source, and costs and benefits of implementing a set of controls on these activities. Agriculture is practiced throughout the country using many different technologies on a variety of soils and in a variety of climates. Conditions, technology and practices, along with a number of other factors determine emissions. Agricultural emissions are highly variable within and across airsheds and must be evaluated carefully."

Thank you.

Attachment:

AUS Consultants study on the economic impacts of the new NAAQS on the agricultural community.