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Air Quality Management Policy for Dairy Operations T he What and How of It All

Air Quality Management Policy for Dairy Operations T he What and How of It All . Presented By YRCAA Staff and Friends, December 10, 2013 Hasan Tahat, PhD – Engineering and Planning Division Supervisor Nichole Embertson, PhD – Whatcom Conservation District

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Air Quality Management Policy for Dairy Operations T he What and How of It All

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  1. Air Quality Management PolicyforDairy Operations The What and How of It All Presented By YRCAA Staff and Friends, December 10, 2013 Hasan Tahat, PhD – Engineering and Planning Division Supervisor Nichole Embertson, PhD – Whatcom Conservation District Pius Ndegwa, PhD – Washington State University Gary W. Pruitt – Executive Director Jeff Harlow – USDA National Resources Conservation Services

  2. How We Got Here Gary Pruitt July, 2010: Board directed staff to address air emissions from dairies August 2010: Dairy work group assembled December 2010: Staff completed drafting the policy February 2011: Board approved the policy for a pilot research project March 2012: Board approved the policy for a trial implementation period of one year June 2013: Board approved the policy as final

  3. What’s the Purpose? Provide guidance and establish requirements for effective prevention of air emissions from dairies Objectives to achieve the purpose • Prevention of emissions adequate to assure compliance with applicable laws and regulations; • Describe a menu of system and pollutant-specific BMPs that will be implemented through the use of flexible, site-specific Air Quality Management Plans; • Clarify what constitutes "reasonable precautions to prevent" emissions as required by WAC 173-400-040(4); and • Inform producers about effective measures for the prevention of air emissions and provide a means by which they can demonstrate that they are taking reasonable precautions to protect the air quality in Yakima County.

  4. How Does It Work? • Prepare and submit an annual Air Quality Management Plan (AQMP), and pay a registration fee; • An AQMP must identify BMPs to reduce air emissions from each system of operation; • YRCAA and the dairy will work together in good faith toward development of an AQMP which is acceptable to both the dairy and YRCAA; • A dairy must fully implement the AQMP according to the criteria and implementation schedules outlined in the plan; • YRCAA may initiate good faith discussion with a dairy to modify any AQMP which is determined by YRCAA not sufficiently effective in minimizing fugitive emissions; • YRCAA will conduct one or more site visits to verify, and to determine the level of implementation of, BMPs; and • Dairies will receive a report and an evaluation score sheet which will identify opportunities for improvement.

  5. How to Use the Information • Appendix A: Understand the statutory authority and regulatory requirements; • Appendix B: Understand which BMPs address which pollutants; • Appendix C: Understand which BMPs can be applied in which systems and functional areas; • Appendix D: Understand the descriptions of BMPs, how and why they work to reduce emissions; • Appendix E: Is a quick reference table for selecting BMPs which target specific pollutants and specific systems; and • Appendix F: Understand the tiered approach to selecting and improving upon the effectiveness of BMPs. • Appendix G: Understand how the score sheet is used.

  6. How to Select, Implement and Improve upon BMPs - A Tiered Approach Nichole Embertson, PhD - WCD and Pius Ndegwa, PhD - WSU • Increasing level of economic, technical, and time input • Accommodates a level of good management For each source: Implement Tier 1 BMP Objectively Assess if the set goal is being met Is goal met or Tier 3 BMP reached? No Go to the NEXT tier BMP Yes Go to the NEXT source

  7. List All Emission Sources First, list all the sources of emissions on the dairy. The following sources include the most common areas of air emissions of a dairy operation. Not all areas may apply to your farm. Select the sources that do apply and list the specific factors (i.e., production areas) within that source that can contribute to air pollutant emission (e.g., Manure Management may include manure holding pit, lagoon, and compost pile as areas within the source that can contribute emissions). 1. Nutrition 6. Grazing Management 2. Feed Management 7. Manure Management 3. Milk Parlor 8. Land Application 4. Housing – Freestall 9. Other 5. Housing - Drylot

  8. List Expected Pollutants Next, for each source, list the expected pollutants in order of importance. For each source, the pollutants of concern have been listed below in general order of importance. Your farm may choose a different order. Nutrition: NH3, CH4, H2S, N2O. Feed Management: VOC, PM, Odor. Milk Parlor: NH3, VOC, Odor, H2S. Housing- Freestall Barns: NH3, VOC, Odor, CH4, H2S. Housing- Drylot Pens: NH3, PM, Odor, H2S, CH4, VOC, N2O. Grazing Management: NH3, N2O. Manure Management– Liquid: NH3, H2S, CH4, Odor, VOC; Solid: NH3, H2S, PM, CH4. Land Application: NH3, PM, Odor, N2O.

  9. List Sources in Order of Importance List the sources in order of importance with respect to each pollutant of concern, the primary sources that emit that pollutant have been listed below in order of importance. Your farm may choose a different order. For example, Ammonia (NH3) a. Nutrition b. Housing - Freestall Barns c. Housing - Drylot Pens d. Milk Parlor e. Land Application f. Manure Management g. Grazing Management h. Feed Management

  10. Define Goal(s) Next, define the emissions mitigation goal for each of the sources. Goals should be specific to your farm, objectives, and source emissions. List goals for each source. The goal for individual sources, for example, could be: • To address existing regulations • To minimize nuisance complaints • To champion environmental stewardship • To address the most important pollutant in terms of volume or health impact • To address other goals

  11. Select BMP - A Tiered Approach Next, list three BMPs to address the goal based on a three-tier-system with respect to effectiveness, cost, ease of implementation, compatibility with other BMPs, and compatibility with your nutrient management plans. Tier 1 being the least expensive and easiest to implement. Tier 3 being the most advanced and most expensive to implement. Tier 1, 2, and 3 level BMPs have been listed for each source in the policy text. The lists correlate to the BMPs listed in Appendix D. The lists are not exhaustive and tier level BMPs may vary for your individual farm.

  12. Implementation For each source: Implement Tier 1 BMP Objectively Assess if the set goal is being met Is goal met or Tier 3 BMP reached? No Go to the NEXT tier BMP Yes Go to the NEXT source

  13. BMP Selection - Example For example the BMPs of each tier level for Nutrition are: Tier 1 - Properly Manage Level of Dietary Protein (%CP) in Diet to Match an Animal’s Needs (NH3, N2O, Odor); Properly Manage and Minimize Overfeeding Sulfur in the Diet (H2S, Odor). Tier 2 - Practice Group and/or Stage of Lactation Feeding (NH3). Tier 3 - Increase the Level or Quality of Starch in the Diet (CH4); Utilize feed additives to maximize efficiency (NH3, H2S, CH4). The following table from the policy summarizes tier-level BMPs for each source.

  14. Air Quality Management Plans Hasan Tahat 1. Attach/enclose a map, aerial photo or drawing of the operation which represents the layout of the operation and provides enough detail to allow YRCAA to adequately review the feasibility and appropriateness of various BMPs for the facility. Include maps or aerial photos of properties used for land application of nutrients 2. Provide the annual averages in animal numbers, the actual maximum number of cattle which can be confined annually and the average weight of each category: Milking; Dry; Heifer; and Calf. 3. Provide the total annual herd milk production in hundred weight and the daily average per cow in pounds. 4. List lands where nutrients are applied, the application method(s) used, and any limitations (weather, field conditions, etc.) which would impact the operation’s ability to utilize any BMP.

  15. Air Quality Management Plans 5. Give the quantity in tons or gallons of nutrients imported and exported to and from the dairy 6. Describe any site-specific features or characteristics which require BMP flexibility or adaptation to meet the needs of the operation. 7. Rank the following pollutants in the order most important to your dairy: Particulate Matter ; Odor; Volatile Organic Compounds (VOCs); Oxides of Nitrogen (NOx); Hydrogen Sulfide (H2S); Ammonia (NH3); Methane (CH4); Nitrous Oxide (N2O) 8. List BMPs by number, (see Appendix C) which will be applied for emission reductions from the following systems: Nutrition; Feed management ; Housing, both drylot and freestall; Manure management; Land application (both fertilizer and manure application); Grazing management; Other

  16. Air Quality Management Plans 9. Attach/enclose an operational plan for implementing selected BMPs which describes the criteria used to determine for which system of operation to implement each BMP listed in #8. The plan should include a method for selecting, implementing, monitoring, and recording activities necessary for employment of each BMP. 10. List BMPs (by number) proposed for future implementation with target dates for each. 12. Certification and Permission I the undersigned do hereby certify that the foregoing is to the best of my knowledge, after reasonable inquiry, true and accurate. I also grant permission to YRCAA to enter the above-mentioned properties at reasonable times for the purpose of inspection.

  17. Air Quality Management Plans Hasan Tahat If You Need Assistance: Contact us and request assistance Plans do not have to be fully completed when submitted. If submitting an incomplete plan, enter as much information as possible, sign the plan and include a request for assistance. You can come to our office or the plan can be completed at the time of your site visit. Contact South Yakima Conservation District Laurie and Landon will be fully trained and capable of providing assistance. Employee the services of a technical service provider. We are available to train qualified providers and will develop a list of such providers.

  18. BMP Evaluations One or more site visits will be conducted to evaluate BMPs. Findings will be summarized on a Score Sheet. • Collaboration between: Drs. Hasan Tahat, Nichole Embertson, and Pius Ndegwa • Provides a scientific basis for weighting BMPs and evaluating them for effectiveness • Allows consideration of individual pollutants and sources • A copy of the score sheet will be provided with the site visit report

  19. Findings From the work accomplished thus far: The vast majority of recommended BMPs are found to be economically feasible and all are found to be technically feasible. Some BMPs naturally come at a higher cost but using a tiered approach allows for planning improvements to higher-tier BMPs to be incorporated into the farm plan for the future. Dairies are implementing most of the recommended BMPs and some dairies are searching for further solutions to reduce air emissions, even at higher costs.

  20. Findings, Cont. Some opportunities for improvement: • More frequent removal of manure from dry lot pens; • Stockpiling manure outside the pen; • Increasing the frequency of freestall flushing; • Knocking down and removing fence line manure more frequently; and • Injecting or incorporating manure into the soil within 24 hours of land application.

  21. Conclusion Change is never easy. However, by complying with the policy, you join a very proactive and visionary group of producers who believe that working within existing air regulations under the provisions of a local policy is the best course of action for Yakima Valley dairies and their neighbors. We will be flexible and will work with the industry and the Ag Task Force to help determine how best to sustain the policy. Producers who already implement the policy find the policy to be effective and both economically and technically feasible.

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