The National Cattlemen's Beef Association clearly spelled out its opposition to any attempt by the Environmental Protection Agency (EPA) to lower the coarse particulate matter (PM) National Ambient Air Quality Standard (NAAQS) in its official comments submitted to the agency last week.
PM, which includes both urban and rural dust, is regulated under the Clean Air Act. Cattle ranches in arid states can have a difficult time meeting the PM standard due to windblown dust and dust kicked up by cattle movements. Because of arid climates and natural phenomenon, it is difficult for some cattle operations to ensure compliance with the current standard despite the use of best management practices.
"The fact is there is only so much that farmers and ranchers can do to mitigate dust on their operations. Mother Nature controls the rest," said Ashley McDonald, NCBA deputy environmental counsel. "Our members implement dust control measures, ranging from soil conservation to fugitive dust control plans using best available control measures, which they implement every day of every year while supplying America with the food that it needs."
If EPA chooses to lower the dust standard in the final rule, cattle producers may be faced with increased regulation and other negative consequences. "A more stringent PM standard will lead to employment impacts and economic dislocation. Current operations have a difficult time meeting the current PM standard and further tightening the standard would have disastrous effects on America's rural economies," the comments state, adding that a tougher standard would, "disproportionately affect those very areas where rural, coarse PM predominates and would result in economic dislocation with documented health impacts."
McDonald made it clear that if the PM NAAQS is further reduced, it will be virtually impossible for current agricultural facilities, including feedlot operations, to demonstrate compliance despite the lack of evidence showing any negative health effects from rural dust at normal levels.
"Over the past 30 plus years, many experienced medical and public health experts in respiratory diseases, epidemiology, toxicology and clinical treatment have noted that coarse PM has never been demonstrated to have adverse health effects at ambient levels," said McDonald. "The PM standard should be based on sound science. EPA has not presented such evidence; therefore the standard should not be lowered."
EPA intends to publish a final PM standard by Dec. 14.