Submitted to: Western Dairy Air Quality Symposium
Publication Type: Proceedings
Publication Acceptance Date: 4/15/2011
Publication Date: 4/20/2011
Citation: Funk, P.A. 2011. The economics of air quality regulation: the true costs of increased PM2.5 regulation. Western Dairy Air Quality Symposium. April 20-21, 2011, Sacramento, CA. Available: http://www.westerndairies.org/2011symposium/17Funk.pdf.
Interpretive Summary: Milk prices have been below production costs for two of the past three years, yet in jurisdictions requiring air permits dairies must invest in control technology to comply with air quality regulations. The measurement and mitigation of uncontrolled area-source (fugitive) emissions (most dairy emissions fall in this category) is not yet a well-established science. This article calls for caution on the part of state and regional air regulators, suggesting careful calculation of costs and benefits before promulgation of novel technologies. Some examples are included.
Technical Abstract: Potential best available control technologies (BACT) are being considered for promulgation by the San Joaquin Valley Air Pollution Control District and other jurisdictions in response to determinations of national ambient air quality standards non-attainment for ozone and PM2.5 by writing dairy-specific state implementation plans. While California dairies already practice many of the proposed techniques (such as scraping corrals and flushing feed lanes), implementing others might require dairies to make major capital investments, even though total air quality benefits are not well established. An analysis for cotton gin dust emissions showed that power plant emissions increases exceeded source reductions for some types of additional control technology. In the case of proposed regulations for vehicle exhaust emissions the USEPA carefully calculated all the costs and benefits. A similar careful analysis for dairies may prevent regulatory and financial investment in technologies that fail to deliver desired regional reductions in PM2.5 and levels of PM2.5 and ozone precursors. Technologies that may benefit from more detailed analysis of the total environmental and economic costs and benefits include paving part of the corral, enclosing the milk parlor, planting windbreaks, watering unpaved surfaces, shade construction, and biogas engine-generator installation. Spending limited resources only on technologies that will make a large net impact on regional air quality will reduce frustration on the part of both milk producers and regulators.