This often leads to identification of sources and practices to reduce the emission of the pollutant within the affected region.
Currently there are six EPA designated criteria pollutants: 1) carbon monoxide, 2) nitrogen dioxide, 3) ozone, 4) lead, 5) sulfur dioxide, and 6) particulate matter.
Under Section 109(d) of the Clean Air Act, the EPA Administrator and independent scientific review committee must re-evaluate both the list of criteria pollutants and the NAAQS in five-year intervals. The ozone standards were recently reviewed and recommendations are expected out soon.
If the Environmental Integrity Project’s petition is successful and ammonia is listed as a criteria pollutant, the action has the potential to significantly impact food production. Agriculture (both animal and crop agriculture) is the largest source of ammonia emissions. Development of primary and secondary standards under the Clean Air Act for ammonia could mean that mitigation is required for point sources (like CAFOs) that exceed the standards.
This could also mean that some of the CAFOs will require permits under Title V. States with designated authority will oversee the permitting process and enforce standards.
“There are practices that can reduce ammonia — all with varying costs and levels of effectiveness,” notes Powers. “This spans reducing diet crude protein, to installing manure covers, applying urease inhibitors on fields, injecting manures. IF this moves forward, the best option is for EPA to propose an extensive menu of options with identified mitigation coefficients so that a farmer can determine which options fit best with the farming system.”
This petition follows a recent report from the Environmental Integrity Project that interpreted findings of an industry-funded EPA study that monitored ammonia, particulates, hydrogen sulfide, and volatile organic compounds from CAFOs across the country.