Presented by Bob L. Vice, President
California Farm Bureau Federation
American Farm Bureau Federation
April 29, 1997

Thank you, Mr. Chairman, for the opportunity to provide testimony for this important hearing on air quality. I am Bob Vice. I own and operate a wholesale citrus and avocado nursery and farm avocados near Fallbrook, California. I am President of the California 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. Our members grow every type of farm commodity found in America. I am pleased to have the opportunity to discuss with you today the impacts of new air standards on the agricultural community. My comments focus primarily on the Environmental Protection Agency's proposal to revise the National Ambient Air Quality Standard (NAAQS) for particulate matter.

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 that was adopted by delegates to our annual meeting. It clearly outlines the position of America's farmers and ranchers 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; seek 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 by farmers and ranchers 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 and cover crops, and plant trees and vegetation for windbreaks.

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 windblown 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 tons per acre per year). And soil lost to wind erosion continues to decrease as farmers expand these extremely environmentally beneficial practices (Attachment I). Farmers are cleaning the air and should get credit for those activities.

Make no mistake: we are all for clean air, and this debate today is about how to continue to achieve those goals.

Agriculture is concerned because EPA estimates that 34.3 percent of fine particulate matter can be attributed to agriculture and forestry. Regarding this questionably large estimate, 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 EPA for cattle feed yards, feed mills, grain elevators and dust from farmers' field operations.

Those comments were made last week 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 these standards, how much it will cost the agriculture industry and the consuming public, and how much agriculture activity actually contributes to air pollution problems. (Attachment II).

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 (Attachment Ill).


Today, however, I want to focus on actual situations those of us involved in California agriculture already face in regard to the present PM-10 Non-Attainment Area for central and southern California, as determined by the 1990 Amendments to the Clean Air Act. Under this status, a major portion of California's agriculture has been faced with a number of challenges which, in many cases, are yet to be resolved. Agriculture in other areas of the country may face the same situation if a new PM standard is imposed.

The money, time and resources we have spent attempting to meet the PM-10 ambient air quality standard have given us plenty of reasons to know 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 of our 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 eight 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 three or more years, not eight per year, and farmers don't even disc rice or rangeland at all, much less 13 and two times 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 taking into account that water is of 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 over 31,000 permits would need to be written for farms. Each silage pile, unpaved road and equipment storage yard, to name a few, would have been permitted. The District estimated that it would need 70 additional permitting engineers to process air quality permits just for farms.

EXAMPLE 3: As I indicated, information used by the air districts identifies agriculture as a primary source of PM-I 0 emissions. For the past five 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 the 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 concerns with PM-10 estimates, many of which are still unaddressed and uncorrected. Furthermore, other PM-10 issues are still arising. For example, EPA is also looking at 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 are 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 (Attachment Ill).

Considering all these discrepancies, it is unbelievable that 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 emphasize the necessity to fully study PM-2.5 before deadlines are set and rules are developed.


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 on 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. 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 costly implementation activities, attainment deadlines and regulations are set in place for yet a new PM standard.


In conclusion, I want to reiterate that much work is yet to be done in the agriculture industry before a new standard is set 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 and formation of PM-2.5, so as not to make the same mistakes that we are making with agricultural PM-10 emissions.

A shotgun approach will only serve to put American agriculture out of competition 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 price makers." Therefore, any increase in operational costs of farming becomes significant and must be based on accurate information that justifies the expenditures.

We also want to be careful in not tipping the balance of regulation in this country to far as to 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, but it 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 must continue to demand that the concerns of America's farmers and ranchers are addressed by the EPA 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 USDA's Natural Resources Conservation Service, as he remarked in last week'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.