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Clearing the Air

Clearing the Air. Feedyard Air Quality Management Program (FAQMP). Shelley Howard and Brent Auvermann Texas Cooperative Extension Amarillo, TX. Regulatory Incentives for EMS Adoption by Industries in Texas. On-site technical assistance (!)

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Clearing the Air

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  1. Clearing the Air Feedyard Air Quality Management Program (FAQMP) Shelley Howard and Brent Auvermann Texas Cooperative Extension Amarillo, TX

  2. Regulatory Incentives for EMS Adoption by Industries in Texas • On-site technical assistance (!) • Modify regulatory requirements that do not change emission or discharge limits • Lower priority for EPA compliance inspections • Extra credit on compliance-history score • Reduced fees for EMS implementation training • Incentives available depend on intensity of EMS

  3. Minimum Standards for EMS in Texas • Environmental Policy Statement • Specifies intent of environmental improvement • Documents intended performance improvement and compliance assurance • Planning Phase • Describes the scope of the EMS • Identifies and prioritizes environmental aspects of operation as indicated by self-assessment • Implementation Phase • Assigns clear responsibility to ensure regulatory compliance • Keeps accurate records/documentation

  4. Beef Sector Focus

  5. Texas’ Regulatory Situation • NPDES delegated authority received 1999 • Subchapter B (State CAFO rules) among the U.S.’ most comprehensive, strict • Pollution prevention plans • Setback distances from “permanent odor sources” • Setbacks dependent on neighbor consent, “odor management plans” • Generic nuisance provision

  6. Background • Stakeholder/producer group • Texas Cattle Feeders Association (TCFA) • Six cattle-feeding corporations representing over 25 cattle feedyards (1.5 million head total) including yards in TX, OK, NM, KS, CO • Regional avg. feedyard capacity: 40,000 hd • Tools for air-quality management are the highest environmental priority of Texas’ cattle-feeding industry

  7. Why the Air-Quality Focus? • Local concerns • Nuisance dust, odor <> neighbor relations • Visibility and liability on major roadways • Employee turnover • Animal health and productivity • Regulatory concerns • Today: ambient air-quality standards • Tomorrow: major-source emissions fees? • Tomorrow: Superfund exposure 

  8. EMS FAQMP

  9. FAQMP: Why? • Comprehensive EMS has been a hard sell to Texas’ highly regulated cattle feeders • There is great value in “EMS thinking,” but cattle feeders need a more concrete motivation • Need a more targeted, non-duplicative program to address the clearly stated need • Corresponds to active research focus • FAQMP success will lead to EMS • Stakeholders expect EPA to “adopt” EMS

  10. Feedyard Air Quality Management Systems (FAQMS) in Texas • An EMS scaled down to focus on environmental risks not prescriptively regulated by Texas’ delegated permit authority under NPDES • Focuses on nuisance air pollution and current and future air-quality regulations • May serve as an “odor control plan” to reduce setback requirements for new or expanding CFOs

  11. Performance Measurement • Stakeholders focused on performance: “How do we know how we’re doing?” • Feedyard managers need a quick and easy way to measure air quality • Dust: Use visibility as an indicator? • Testing contrast-based color array • Researching software techniques to read contrast – human perception not required

  12. Identifying Air Pollution Risks RISK Air Pollutants Receptor Impacts

  13. Lessons Learned • New environmental stewardship initiatives like the EMS must complement and enhance what the producer is already doing instead of duplicating and complicating it • Integrating the EMS project with ongoing research emphases made the project more immediately relevant to the needs of our stakeholders • The EMS project gave us a prime opportunity to help our stakeholders prepare to meet tomorrow’s air-quality challenges

  14. The EMS pilot project has given us a great philosophical context for talking about tomorrow’s environmental challenges with an industry whose fortunes rise and fall on today’s news bulletins

  15. Reflections on the Process

  16. Principles of Constructive Discourse • Establish common ground in principles • Establish common ground in facts • “Seek first to understand, then to be understood” • Avoid imposing zero-sum constraints • Abandon arguments with low credibility

  17. “Agricultural producers are the original conservationists.”

  18. The right to claim the “conservationist” label is less a matter of Cultural heritage or family identity than A business ethic based on and demonstrative of stewardship principles

  19. Kevin RollinsPresident, Dell Inc. “Paraphrasing Solzhenitsyn, ‘I’ve lived my life in a society where there was no rule of law. And that’s a terrible existence. But a society where the rule of law is the only standard of ethical behavior is equally bad’… We believe you have to aspire to something higher than what’s legal.”

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