Nov 13, 2009

EPA’s reckless abandon

It appears to me that the Environmental Protection Agency (EPA) is getting to the point where they can choose industries that will be winners and losers in this economy. EPA has recently changed their thinking on coarse particulate matter and reduced acceptable levels by 90 percent compared to their prior regulation.

If this rule is adopted by EPA, most agricultural operations would not be able to comply. It’s almost unconscionable that EPA could consider a change of this magnitude. EPA must reevaluate the National Ambient Air Quality Standards every five years and the research that they used several years ago was deemed incomplete by the agency. But now they seem to think that the same research has increased in credibility without being amended.

Coarse particulate matter is the dust that trucks going down a dirt road would kick up, or dust from trailing cattle from one pasture to another. Harvesting just about any field crop and, of course, tilling fields would also create coarse particulate matter. Reducing the allowable level from 150 micrograms to 12-15 micrograms is an unreasonable expectation and appears to be unjustifiable. Unfortunately, EPA doesn’t have to consider economic impacts when making decisions or proposing changes to current rules.

Ironically, these proposed ambient air standards will directly affect seven national parks in Arizona because of their exceptionally dry climate. I would have to imagine that many of the Indian reservations would also be affected. However, I wonder if the regulations would be enforced there because EPA hands out a lot of money to the reservations.

Just think about it. If you’re moving cattle, you’re susceptible to a fine by EPA. And from what I’ve seen, they are not bashful about fining anybody. Feedlots, even though most already have dust abatement systems in place, would have problems complying with the new regulations.

Fifteen micrograms is a very fine line for particulate mater. Typical ambient air, that we breathe every day, contains about 35 million particles per cubic meter. A typical home would have levels of about 1 million particles per cubic meter. A clean room, used for manufacturing computer chips, is 1,000 particles per cubic meter. A microgram is the equivalent of 0.0002 ounces. These are essentially unreasonable specifications.

Tamara Thies, the National Cattlemen’s Beef Association’s (NCBA) chief environmental council, said the "EPA is suggesting a level of 12 to 15 micrograms of dust per cubic meter of air." That is below naturally occurring levels of dust throughout many western states, including pristine national parks.

"If EPA were to set the air standards at this level, much of the country would be over the limit. Cattle producers are concerned about this because it would limit our ability to raise livestock, who kick up dust as they walk around," she explained. "But this issue goes well beyond agriculture. States would be required to impose extreme control requirements and limitations on many businesses to ensure that the standard is met."

NCBA is not fighting this alone and has formed a coalition with several mining groups and other ag organizations to fight this issue. Thies also said "We are urging EPA to reject this faulty study and refrain from setting an air quality standard for dust lower than naturally occurring levels, and effectively halting economic growth and development."

I would suggest that states and counties get involved in this debate. I was told by NCBA’s Collin Woodall that the decision will ultimately become EPA Administrator Lisa Jackson’s. It would then have to go through the standard rule making process where the Office of Management and Budget will get involved.

EPA has become a very powerful arm of government and it makes one wonder where this directive came from, or if it's Jackson’s own initiative. EPA has gotten out of control and needs to be hemmed in. It’s clear that this latest move is arbitrary and capricious. It shows us another example of how government has become too big and too controlling.

I can’t wait until we get back into the battle of climate change. Feedlots have already been asked to measure their contribution to greenhouse gasses, including carbon dioxide emissions which, according to EPA, are a health hazard. Folks, you’ve got to get your states, county commissioners, and city governments involved in this issue. This is economic suicide for all resource industries. — PETE CROW