A Dusty Conclusion

This issue partly caught my eye because it is an excellent example of what is wrong with not only EPA, but also most of big government. In a suit of arrogance and powered by an ego-driven engine, EPA believes they are big enough to change anything they choose. This obnoxious confidence in who they think they are leads them to create laws and regulations before they have any solid ideas for how to meet the new standards. This cart-before-the-horse approach causes a lot of confusion and wastes tons of resources.

EPA is way out of their league on this one.

As usual, we must wait to see what happens.

Can We Beat Dusty?

Tell me, if you can, exactly how will U.S. EPA reduce the amount of particulate leaving a farm? In one of the earlier pieces of this series I mentioned the control of dust at manufacturing facilities. Consider these standard approaches for controlling dust on a smaller scale:

1. spraying a parking lot or roadway with water at least once a day, and possibly more.
2. using water mixed with an organic emulsion to spray the dusty area (use of oil or petroleum products is no longer legal).
3. paving the area
4. reducing the speed of all vehicles that travel the dusty area, so less particulate is kicked up

That is about the extent of available dust control methods. You tell me, which of these is in any way possible for a farm?

By the way, there is a reason that soybeans are harvested when they are dry. If they are not dry, they will have to be dried prior to storage. (Think of the carbon emissions!)

Let EPA Take On Dusty

At this point, those representing the farming community are not making noise about the cost of determining current ambient concentrations. They are more concerned about the effect caused by approving the new lower ambient air quality standard. Once the new standards are approved, EPA will be required by law to demonstrate where the standards are being met and where not. This new standard could potentially create the scenario where a county that has never exceeded an ambient air quality standard, is now non-attainment for particulate.

EPA will need to determine what areas of the country do not meet the new standard. Then it will determine who is contributing to the excess of particulate emissions and develop programs to bring the particulate concentration below the final standard.

Farmers are quite smart to not want EPA to have this control!

How Dusty Am I?

When farmers hear of the proposed regulation, no doubt they wonder where they stand with regard to the new standard. Are they already generating dust at a level that exceeds the standard? Or, do they have nothing to worry about? Maybe they almost meet the new standard, but not quite.

How can they find out? The concentration of particulate in the ambient air leaving their farm is most likely determined in one of two ways:

1. The most direct approach is to use ambient air sampling equipment to measure the concentration of particulate leaving the farm. This ambient monitoring program must take into account variable wind conditions, and also variability of activity on the farm. Ultimately you want to prove that the ‘most dusty’ conditions still meet the ambient air quality standard.
2. The second approach may not be so obvious. It involves running air dispersion computer models. Necessary input data includes information about the property, wind conditions, level of activity on the farm and days with rainfall. Other parameters may also be required to represent real world conditions to the computer model. The computer model is run and generates a grid of anticipated high ambient concentrations.

Both of these methods will cost the farmer money, and I am not talking pocket change. Is this really a good idea?

Define Dusty

So how dusty is too dusty? Exactly what is the EPA proposal that has farmers concerned?

According to the letter from the 21 Senators, the issue involves EPA’s current review of the NAAQS (national ambient air quality standard) for particulate. The Clean Air Act requires an EPA review of these air quality standards every 5 years. The air quality standard is the benchmark that determines the amount of particulate matter allowable before generating health concerns.

The existing NAAQS for particulate is 150 ug/M3. That is micro-grams of particulate per cubic meter of air. EPA’s recent proposal involves reducing this standard to 65 – 85 ug/M3, making the new standard twice as stringent as the old.

Big Dusty Deal or Not?

So what do you think about the EPA intending to control the dust generated on farms?

When dust is kicked up on a farm, some of the particles are large enough they will settle out and fall back to the ground. The concern for EPA is the smaller particles that remain airborne and eventually become part of the air you and I breathe. The inhalation of particles from all kinds of sources is proving to be more of a health concern. Shall we all agree that the EPA is on the right track?

Maybe not. A letter addressed to Lisa Jackson, US EPA Administrator is contains this statement: “We respect efforts for a clean and healthy environment, but not at the expense of common sense.” This letter is signed by 21 of the U.S. Senators.

Don’t pitch your common sense just yet!

Dusty is the Farmer?

Apparently the U.S. EPA is giving consideration as to how they can crackdown on farm dust. Farm dust can be generated by livestock walking, the harvesting of soybeans on a dry day or a vehicle driving on a gravel road. These and similar activities occur frequently on any working farm.

Many who have worked in industry have experienced how hard it is to control dust from a parking lot or material handling operation. That is absolutely peanuts compared to controlling dust from farm activities!