Dairy Farmers Welcome EPA Decision to Close Out Two-Decade-Old Air Emissions Study

The National Milk Producers Federation (NMPF) welcomed the U.S. Environmental Protection Agency’s announcement that it will not finalize air emissions estimating methodologies under the 2005 Animal Feeding Operations Air Compliance Agreement, and that it will move to terminate the agreement. The decision ends more than 20 years of uncertainty for the dairy farms and other livestock operations that volunteered for the National Air Emissions Monitoring Study (NAEMS).

“Dairy farmers signed up for this study in good faith two decades ago, and they’ve been waiting ever since to find out what it would mean for their farms,” said Gregg Doud, president and CEO of NMPF. “You can’t measure a handful of farms years ago and use those numbers to set expectations for thousands of other farms. We appreciate EPA following the data and giving farmers a clear, final answer.”

In comments filed last year, NMPF told EPA that its draft dairy emissions models were built on monitoring data from only five dairies. NMPF’s technical analysis found that the models produced per-cow emission estimates that swung dramatically with herd size, predicted negative emissions in below-freezing weather, and offered no way to account for the advances in feed, genetics, manure management and emissions control that dairy farmers have adopted since the data were collected.

EPA’s announcement reflects many of these concerns. The agency concluded the data are too old and too limited to support reliable methods and no longer reflect current barn designs, herd sizes and manure practices.

“There’s a saying in our industry: when you’ve seen one dairy farm, you’ve seen one dairy farm,” said Clay Detlefsen, senior vice president and staff counsel at NMPF. “That’s why this approach was never going to work. Farms vary too much from one another and change too much over time. We’re grateful to EPA staff for their professionalism over the years, and we look forward to continued collaboration on practical, science-based approaches.”

U.S. dairy farmers have a long record of continuous environmental improvement, and NMPF will keep working with EPA, USDA, land-grant universities and its member cooperatives to build on that progress.

EPA’s decision marks the second win for dairy farmers in the last week. On Oct. 29, USDA announced $165.5 million in Section 32 dairy purchases, which NMPF welcomed as timely support for demand during a difficult stretch for milk prices.

EPA Releases Draft NAEMS Dairy Emission Models

EPA released July 14 the preliminary draft report on ammonia, hydrogen sulfide, and particulate matter emission models for dairy operations developed using data gathered during the National Air Emissions Monitoring Study (NAEMS). The report is now available via the NAEMS project site.

The report’s release will be followed by EPA’s draft report on Volatile Organic Compounds (VOC) emission models for dairy farms, set for release later this year. Once the second report is released, EPA will then take time to revise and improve the preliminary draft models for all animal types. Once all the models have been reviewed and revised, EPA will release the entire set of revised draft models for a formal public comment period currently scheduled for mid-year 2023 with finalization by that year’s end. NMPF will be reviewing the current and future drafts to provide comment to EPA.

The NAEMS was established in 2006 by a voluntary Air Compliance Agreement between the EPA and the pork, dairy, egg and broiler industries, to address the lack of scientific data. Funded through a one-time authorization through the national dairy checkoff, dairy farmers provided the financial support for NAEMS so that emissions data could be collected at select sites to first, accurately assess emissions from livestock operations and compile a database for estimation of emission rates, and second, promote a national consensus for emissions-estimation methods and procedures from livestock operations.