SPEAKERS CONTENTS INSERTS
Page 1 TOP OF DOCOVERSIGHT OF AIR QUALITY ISSUES RELATING TO THE AGRICULTURAL INDUSTRY
WEDNESDAY, APRIL 23, 1997
House of Representatives,
Subcommittee on Forestry,
Resource Conservation, and Research,
Committee on Agriculture,
The subcommittee met, pursuant to call, at 9:35 a.m., in room 1300, Longworth House Office Building, Hon. Larry Combest (chairman of the subcommittee) presiding.
Present: Representatives Smith of Michigan, Lucas, Lewis, Chenoweth, Moran, Schaffer, Jenkins, Cooksey, Dooley, Stabenow, John, Peterson, Clayton, Minge, Baldacci, Berry, Goode, Stenholm.
Also present: Representative Nethercutt.
Staff present: John E. Hogan, chief counsel; Dave Ebersole, senior professional staff; Russell Laird, director, Subcommittee on Forestry, Resource Conservation, and Research, John Goldberg, professional staff; Joy Mulinex, congressional fellow; Candace Brassard, congressional fellow; Callista Bisek, assistant clerk; Wanda Worsham, clerk; Danielle Farmer, minority staff consultant.
Mr. COMBEST. The hearing of the Subcommittee on Forestry, Resource Conservation, and Research, to provide oversight on air quality issues and their effects on the agricultural industry shall come to order.
OPENING STATEMENT OF HON. LARRY COMBEST, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF TEXAS
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Mr. COMBEST. Good morning and welcome to everyone here. I would like to thank our witnesses for the time and effort to share their views with us on this important subject.
This hearing is being conducted to provide oversight of air quality issues and their effect on the agricultural industry. Our hearing is one of a series of hearings being held in both bodies of Congress. Due to the magnitude of EPA's proposal, several committees in the House are examining this issue, including Commerce, Small Business, and Government Reform. Similar hearings are also being held in the Senate.
We would like to have a thorough discussion of the USDA Agricultural Air Quality Task Force, which was created in section 391 of the Federal Agricultural Improvement and Reform Act of 1996.
Since air quality issues are particularly important where I am from in west Texas, I was particularly interested in this section during the writing of the farm bill, and I am now very interested in the Department's plans to implement this section and what role this task force will play in these issues.
Next, the subcommittee will examine and discuss the Environmental Protection Agency's proposed new National Ambient Air Quality Standards for particulate matter. This new standard will require monitoring of particulate matter of 2.5 micrometers or less, commonly referred to as PM2.5.
I have always said that our decisions here in Washington should be based more on science and less on emotion. Today, we are privileged to have the benefit of years of experience of several internationally recognized scientific experts in agricultural air quality research.
The witness on our third panel this morning will discuss California's State Implementation Plan for addressing the non-attainment of the PM10 standard. This discussion should be particularly helpful for the members of the subcommittee who are not as familiar with the regulatory burden that can result from these air quality standards. It should be of interest to hear the problems that Mr. Dooley and his neighbors have been faced with.
Page 3 PREV PAGE TOP OF DOC Other members should note that the regulations under the California plan could be a precursor of things to come as other States are declared non-attainment under the more stringent proposed standards of PM2.5.
At the last hearing of this subcommittee, we were discussing with the Department of Agriculture the benefits of the Conservation Reserve Program and the benefits it produces in the way of improved air quality. At that time, officials from the Department testified that they did not feel like the science was yet developed to adequately measure the impact on air quality from the CRP program. It is somewhat ironic that we are here today discussing the EPA proposal which could result in forcing drastic changes in farming practices.
Research is currently being conducted in my hometown of Lubbock, TX, to define the relationship between air speed, wind speed, wind direction, and relative humidity. If anyone has any ideas on how to make the wind stop blowing or increasing the relative humidity in west Texas, I would like to hear from them. But, as far as I know, those are factors that we cannot control.
Of course, we figured out a long time ago that if you can't stop the wind from blowing, then you'd better concentrate on trying to keep the soil in place. Soil conservation is nothing new to me personally, since I come from a farming background. It is pretty simple.
Without soil conservation, you will eventually have no topsoil left, and then you will have nothing to farm on. We want to keep our soil in west Texas so we can farm it. Our neighbors in Dallas don't want it, and we don't want it blowing over to them either.
More importantly, discussions of soil conservation are nothing new to the Agriculture Committee. As one of the only few members to serve on this committee during three farm bills, I can tell you that soil conservation has been a very important part of that discussion. However, it has been frustrating that somehow the EPA has failed to recognize that assisting farmers with soil conservation efforts is the role of the Agriculture Committee in the House and Senate and the Department of Agriculture.
Page 4 PREV PAGE TOP OF DOC EPA's actions on these issues the last few years has been preposterous. A few years ago, EPA declared the city of Lubbock, TX, a non-attainment area under current air quality standards because the dust blows. Fortunately, we showed them the folly of that determination and it was changed. Then, EPA recently came out with their so-called natural events policy. This policy would require burdensome control measures similar to those formerly required only in non-attainment areas for areas such as west Texas where the dust blows.
Again, I appreciate the time that our witnesses have taken to prepare their testimony, to travel, and to appear before this subcommittee. I look forward to that testimony and the discussion.
I recognize Mr. Dooley for any comments he might make.
OPENING STATEMENT OF HON. CALVIN M. DOOLEY, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF CALIFORNIA
Mr. DOOLEY. Thank you, Mr. Chairman. I want to commend you for holding this hearing today. The issues of air quality and Clean Air Act compliance are ones that have impacted my constituents directly for the past several years.
With the new EPA proposal of the 2.5 particulate matter factor, the problems that have been facing the San Joaquin Valley are now being recognized by other parts of the country. It is vitally important that any decision regarding air quality standards be based upon sound science. This requirement must be applied both to the standards that are set by the EPA and the steps taken to meet these standards.
Recent reports regarding the process that was used to formulate the new proposals put forth by the EPA are very troubling. According to these reports, many concerns were raised by a variety of Federal agencies regarding the science used to develop the proposed 2.5 standard. I know from reading these accounts that the USDA had reservations regarding the proposed new standards, and I hope that we will have a chance to discuss those concerns today.
Page 5 PREV PAGE TOP OF DOC I've been working on a bipartisan basis with a number of my colleagues from California for some time now to secure funding to perform the needed research to develop a workable plan to meet the PM10 requirements. This effort has led to a multi-agency approach that involves USDA, EPA, the Department of Defense at Federal level, as well as State and local Governments and private industry.
The information produced through this study will help to develop a plan that will allow California to meet the requirements of the Clean Air Act, and I believe that the California regional PM10/PM2.5 air quality study could provide the science that is needed to justify new measures to meet the requirements of the Clean Air Act. However, until the study is completed, there is little science to justify the new proposed EPA standards.
I am pleased that part of today's hearing will focus on much of the work that has been done in the San Joaquin Valley to comply with the PM10 standard. One of the witnesses who will appear today has been very involved in the development of the State implementation plan that hopefully will use a common sense approach to meet the goals of the Clean Air Act.
I would like to extend a special welcome to Roger Isom of the California Cotton Ginners and Growers Association who will be testifying today.
Mr. Chairman, I believe that this hearing today represents a great opportunity for us to play a constructive role in the development of clean air regulations that meet the needs of all of our constituents without placing an unneeded burden on a particular segment of the population.
Mr. COMBEST. Thank you, Mr. Dooley.
We are joined today by our colleague from Washington, Mr. Nethercutt, who is a member of the Appropriations Committee and on the Agriculture Appropriations Subcommittee and funds all of our programs.
So thank you for being here, Mr. Nethercutt.
I think Mr. Nethercutt had some comments he would like to make. But before I recognize him, I would like to see if any other members of the subcommittee had any comments they would like to make. Mr. Lucas.
Page 6 PREV PAGE TOP OF DOC Mr. LUCAS. I would just like to submit a written opening statement, Mr. Chairman.
[The prepared statement of Mr. Lucas follows:]
PREPARED STATEMENT OF HON. FRANK D. LUCAS, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF OKLAHOMA
I would like to thank the chairman for holding this hearing today. I believe that all of us on this committee should be concerned about the EPA's proposed ozone and particulate matter standards. I must admit that I come to he is hearing today with my mind pretty much made up about what I think about this proposal. I have found no constituency for it and am quite sure that it will have an adverse impact on the agricultural producers of this Nation.
The more we hear about these regulations, the less I like them. I believe the EPA's proposal is the single largest set of environmental regulations ever promulgated. Every study of the proposal seems to reveal that the folks at the EPA should be ashamed of themselves for not utilizing sound science in promulgating this regulation. If enacted today, hundreds of counties throughout the country will fall out of attainment. It is imperative that these regulations be thoughtfully reviewed by both the public and private sectors. We need to know what impact these regulations will have on our rural economies.
Again, I want to thank the chairman. I look forward to the testimony.
Mr. COMBEST. Did any other members have comments?
OPENING STATEMENT OF HON. GEORGE R. NETHERCUTT, JR., A REPRESENTATIVE IN CONGRESS FROM THE STATE OF WASHINGTON
Mr. NETHERCUTT. Thank you, Mr. Chairman, and members of the committee. I appreciate the opportunity to be here and observe and listen and maybe ask a question or two.
I would just say from the standpoint of the Appropriations Subcommittee on Agriculture, we are very concerned about what seems to be some assault on the CRP Program, which is an environmental program that has a direct relationship to protecting air quality and protecting particulate matter levels.
Page 7 PREV PAGE TOP OF DOC And so we're going to be looking very carefully at that in our subcommittee, Mr. Chairman, and also in the full committee coming up. So I am just delighted to have a chance to sit and listen and ask a few questions, and I appreciate your courtesy. Thank you.
Mr. COMBEST. We're glad to have you here Mr. Nethercutt, and you will certainly be recognized along with other members of the subcommittee to entertain questions.
If there are any additional statements from members, they may be included in the record at this point.
[The prepared statements of Mrs. Chenoweth and Mr. Berry follow:]
PREPARED STATEMENT OF HON. HELEN CHENOWETH, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF IDAHO
Thank you Mr. Chairman. I would like to commend the committee for holding this hearing on air quality issues relating to agriculture.
Mr Chairman, I am concerned today with the Environmental Protection Agency proposal to revise the National Ambient Air Quality Standards for two air pollutants--ozone and particulate matter.
The Environmental Protection Agency is under a court-ordered schedule with respect to the PM standard, because of a lawsuit by the American Lung Association. The EPA is mandated to review the standard, but not necessarily change it. However, EPA has decided to conduct both rule makings (ozone and PM) on the same schedule and has proposed changes.
This is not required by the courts.
The EPA takes the position that both standards need to be revised to protect public health. I have learned that there is a diversity of opinions on the justification of changing either standard.
The considerable controversy over the scientific, economic, and political impacts associated with the EPA planned revisions have been apparent in Idaho.
My Idaho farmers believe the standards proposed by the EPA are far too stringent and costly. The effects on Idaho agriculture would include tarp coverings for all dirt hauling equipment, washing all construction rig tires, elimination of sanding of slick roads and if sanded a complete clean up immediately.
Page 8 PREV PAGE TOP OF DOCTom Geary, president of the Idaho Farm Bureau Federation, states and I quote ''The standards are not based upon good science and certainly the health benefits are speculative at best.''
Additionally, even Senator John Chaffee of Rhode Island, whose environmental credentials are impeccable, states the Ambient Air Quality standard proposal by the EPA is far too stringent and costly and the idea should be permanently shelved.
On the same note, I am worried that the ozone standards will potentially place a financial burden on many Idaho farmers. Many Idahoans have explained to me that the ozone standard would create many more non-attainment zones in Idaho with oxygenates being required at considerable expense to all citizens including agriculture.
Mr. Chairman, if this is the case, this simply will not work.
Current studies suggest agriculture may be less of an emitter of PM than presently attributed. Sound scientific evidence is imperative in this case. A more accurate projection of agriculture's contribution of PM emissions of all sizes is needed before a proposal of this magnitude is finalized.
Retention of current standards rather than accepting the proposed EPA air standards would allow for necessary study and discussion regarding the impact of the new standards.
Thank you Mr. Chairman.
PREPARED STATEMENT OF HON. MARION BERRY, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF ARKANSAS
Let me start by thanking the subcommittee chairman, Mr. Combest, and the ranking member, Mr. Dooley, for this hearing. I would also like to thank today's panel members for providing us with testimony on an issue which I believe is very important and worthy of public discussion. It is my hope that this hearing will provide some objective insight. Often agriculture and the environmental groups find themselves at odds with each other. This does not have to be the case. In forums like this, with interested parties at the table debating the facts in good faith, we can strike a balance that everyone can live with.
Page 9 PREV PAGE TOP OF DOCThe issue we have before us today--air quality, specifically the newly proposed particulate matter and ozone standards--is critical and could have significant implications for both the agricultural and manufacturing communities.
I think people would agree that the Clean Air Act has done a great deal in reducing the health risks caused by air pollution. The EPA should be commended for its efforts in the difficult process of implementation. I am greatly concerned, however, that during the process of evaluating these new standards, the EPA has not adequately built a consensus among the scientific community. The consensus is needed to justify the potential economic impact these new standards have.
Environmental regulations, especially those that have a significant economic impact, must be grounded in good science. there seems to be some significant difference in opinion on the data collected, the methods of collection, and the conclusions made from this data. the lack of consensus among the experts greatly concerns me.
As scientists and health experts learn more about the impact of particulate matter and ozone on public health, we should consider revising our standards. However, I believe that the current air quality standards, which have proven very effective in improving air quality, should be maintained while scientific research continues to determine whether additional controls are needed. Once regulations are imposed, by EPA or any other agency, it is nearly impossible to reverse course.
Put simply, before I ask farmers in my district to comply with these proposed environmental standards, I want to feel assured that they will result in greater health protection.
As a farmer and a small businessman, I am acutely aware of the regulatory burdens imposed by the Federal Government, especially with regard to environmental protection. As I understand it, this new standard has put the potential to impose far-reaching restrictions on agriculture production. In my opinion, Federal environmental regulations should strike a balance of protecting our environment while encouraging the growth and development of private industry.
Page 10 PREV PAGE TOP OF DOC Mr. COMBEST. The first panel, who are at the table--and we appreciate them being here--Mr. Paul Johnson, who is the Chief of Natural Resources Conversation Service. Mr. Johnson is accompanied by Dr. Keith Saxton, Research Engineer of the Agricultural Research Service; Mr. George Bluhm, who is National Meteorologist, Designated Federal Official for the Agricultural Air Quality Task Force, Natural Resources Conservation Service. That is going to take a large business card to get all of that on there.
Dr. John McClelland, Associate Director of the Office of Energy and New Uses, Economic Research Service.
Mr. Johnson and all members of the panel, we'll be happy to include any testimony that you wish, including your opening testimony, into the record without objection, and would invite you to present however you would like to, Mr. Johnson.
I would just suggest to not only this group of witnesses, but to the others as well as we get into this, this is an extremely technical area, and I have spent several hours on the plane, and prior to and subsequent to that, looking through testimony and information, and it can cause somewhat of a glaze.
What I would encourage you to do, as much as possible, is to put this in terms that I understand, that way I assure you everyone in this room can understand it. But put it in terms, if you can, of reality, of what we are actually looking at of specific examples, rather than as scientific terms as possible.
And we do have a lot of extremely capable people from the scientific area today, and we think that's very important. But I would just encourage you, to the extent possible, putting it into layman and laywoman's terms.
And I appreciate your being here.
Mr. Johnson, please proceed.
STATEMENT OF PAUL JOHNSON, CHIEF, NATURAL RESOURCES CONSERVATION SERVICE, U.S. DEPARTMENT OF AGRICULTURE
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Mr. JOHNSON. Thank you, Mr. Combest, Mr. Dooley, members of the subcommittee, and others here today. I want to thank you for the opportunity to be with you today to discuss the issue of agriculture and air quality.
I, too, agree with you that it is a very technical subject, and that's why I brought three good people with me. You may direct all your tough questions to them.
I would like to submit for the record the written testimony, but take a couple of minutes, if you will allow me, to try to put some personal perspective into this issue. I think it is very important that we do that.
As I was thinking about this issue, I realized that the last time a chief of this agency was in front of a committee of Congress to deal with air quality and agriculture was probably in April 1935. At that time, we had a great discussion in this country about soil erosion. Our first chief, Hugh Bennett, had for many, many years preached the gospel of soil conservation, we were in the middle of a depression, and we were in the middle of what was called ''the dust bowl'' in those days.
The story goes that he was scheduled for a hearing on the afternoon of I believe it was April 2. He knew that there was a dust cloud coming. In fact, at that time, we had dust clouds that went 3- to 400 miles out into the Atlantic, originating in the Great Plains. He did his best to delay the hearing. I can't imagine how he did that, but they say that he did, and a dust cloud did arrive. And out of that, the committee acted and the Soil Conservation Service was formed, in 1935.
It is a story that I won't vouch for the exact accuracy, but apparently this guy darkened and the Soil Conservation Service came to the rescue.
I mention that because I want us all to understand that we have come a long way since 1935. I think agriculture has a great deal to be proud of, and this Nation has a great deal to be proud of--the fact that we came together for the first time, recognized the importance of private lands in this Nation and their contribution to a healthy environment and a healthy land. And we have made terrific progress since that time.
Page 12 PREV PAGE TOP OF DOC Today, we produce over three times what we produced in 1935 on those same acres. And not only that, the land is healthier than it was then and continues to improve. Within the past 10 years, we witnessed almost a revolution in agriculture and farming practices that have brought about continued improvements in the conservation arena.
You have mentioned the Conservation Reserve Program. And as we go about the second round of this, being able to target it even better, to deal with issues such as wind erosion and the other conservation issues. You've given us a number of tools in the farm bill to continue this effort, and we really look forward to the next 10 years and the opportunity to work with private landowners on this.
I'll mention one practice alone that agriculture is using today that impacts in a very, very positive way on this issue, and that is the issue of no-till, or the new practice of no-till. It reduces wind erosion terrifically, surface water erosion, it improves soil quality, wildlife habitat, water quality. Through the use of no-till, we are sequestering carbon today.
And as we talked about air quality and global climate issues, and so on, there is a terrific opportunity here for agriculture not just to produce food and fiber, but also to farm carbon if you will and to sink carbon back in the soil. And at the same time, these practices make agriculture more productive and economically viable.
I was just in Georgia last week at an agriculture research station there, and we looked at the watershed that they started no-till on in 1974. And today, we have numbers that show that for the first time in 10,000 years in agriculture, we are actually producing soil along with producing crops. I mention this because I want us to recognize that we are making terrific progress in improving environmental benefits and being very productive in caring for this land.
I was just in Guatemala City a couple of weeks ago, and I can tell you that we are doing very well when it comes to air quality in relation to where we were. It was very hard to breathe in that city, and we have made terrific progress. And we need to be thankful for that.
Page 13 PREV PAGE TOP OF DOC Out of the concerns, though, that are being raised today about some of the medical impacts, the health impacts, of small particles and of ozone, the Agriculture Committee last year included Air Quality Task Force as part of the farm bill. Its charge is to determine the extent to which agriculture activities contribute to air pollution and to determine cost effective ways in which the industry can improve air quality. It is also to advise the Secretary on air quality issues affecting rural communities and production agriculture.
In August 1996, we formally requested nominations for this committee. We received over 40 applicants--people who had a broad range of expertise. In January 1997, 20 were selected and accepted their positions. They represent a healthy balance between farmers and ranches, the agriculture industry, scientists, and health advisers, and they represent the entire country. We have representatives from every region of the United States.
The first meeting was held on March 5 and 6 of this year in Washington, and a great deal of time was devoted to the new EPA standards or proposed standards for ozone and PM10 and 2.5.
The task force put forth some proposals on this, and the people with me today who are on that task force will answer specific questions on that. Although a couple of the issues raised--one, that the task force should work together with EPA and EPA should recognize the importance of this task force and the expertise therein--we're working with EPA now on a memorandum of understanding so that they will include the task force as they deliberate on these issues.
Other specific issues raised in that first meeting--one, the importance of considering air quality, along with other resource issues. For example, we are concerned about burning in agriculture, and yet it is a good economic tool and, in many cases, a good ecological tool to use to manage land. And we cannot manage one resource and be blind to others. And it is very important that as we work through these issues we look at all of the resource issues and not just one at a time.
Page 14 PREV PAGE TOP OF DOC They also were very concerned that we make sure and have the best science available, especially when looking at the agriculture impacts. And they reaffirmed our commitment, and the commitment I think that has worked very well over the years of locally led efforts, and to utilize voluntary approaches as much as possible. The next meeting is planned for June 17 through 19 in Fresno.
I think it's important that we recognize that although the clean air standards are certainly on the burner today, there are other issues that this committee will be looking at. The global climate issue is one. I'd like to just mention, as an aside, that I think we have some terrific opportunities in agriculture in dealing with that issue.
We are working on some numbers right now that the committee is going to be looking at in terms of carbon sequestration. I think we have some wonderful opportunities in agriculture to benefit the issue, and look at it as an opportunity. I think we really have some possibilities there.
It's easy to get discouraged about these issues, and we very often become very defensive. I would suggest that we should not be that way, that we have solved these problems in the past and will continue to do so. We will do everything we can in the Department of Agriculture to support good science.
You'll soon be reviewing the agriculture research agenda for the Department of Agriculture, and I would encourage you to take that seriously. I think we should be willing to set realistic goals and then give industry time and flexibility to meet those goals, and we think that we can do so.
Financial and technical assistance are also important, and it's good to see Mr. Nethercutt here today.
In 1937, this country committed themselves to conservation on private lands, and at that time we were putting twice the financial assistance to conservation on private lands as we do today in today's dollars. At that time, we had twice the resources going to working together with farmers and ranchers across the country as we do today.
Page 15 PREV PAGE TOP OF DOC I think it is very important, and I commend you and the administration for working on balancing our budget, but we need to understand that we have an environmental budget as well, and that we need to recognize that they both must be in balance.
I'd like to close with a few words from a publication that we just issued called ''America's Private Lands: A Geography of Hope.'' And in that publication, we are trying to make the case for the good work that is going on on private lands, and that it is a shared responsibility between society and private landowners.
And the most important point that we make in it is that conservation includes, certainly, care of the land. But it also includes a good viable opportunity for people to live on that land and to make a living from it. And in the closing of this book, we cite a quote from Alda Leopold back in 1939, in a speech that he gave entitled ''The Farmer as a Conservationist.''
And it goes like this,
When the land does well for its owner, and the owner does well by his land, when both end up better by reason of their partnership, then we have conservation. When one or the other grows poorer, either in substance, or in character, or in responsiveness to sun, wind, and rain, then we have something else and it's something we do not like.
Let's admit at the onset that harmony between people and land, like harmony between neighbors, is an ideal and one that we will probably never attain. Only glib and ignorant people, unable to feel the mighty currents of history, unable to see the incredible complexity of agriculture itself, can promise any early attainment of that ideal. But any person who respects himself and his land can try.
I think it's a very positive statement, and it's one that I would urge this committee and Congress to take a look at as we go forward. I think we can have healthy land, and I think we can have healthy people, healthy air, healthy water, and a very viable agriculture community. And I think that that is our pledge to work together with you to be able to do that.
Page 16 PREV PAGE TOP OF DOC Thank you. And at this time, we'd be happy to take questions from you.
[The prepared statement of Mr. Johnson appears at the conclusion of the hearing.]
Mr. COMBEST. Thank you, Mr. Johnson. Do any of your colleagues have statements or comments they needed to make at this point?
Mr. JOHNSON. I would mention that Dr. McClelland has been on the interagency task force working on the EPA issues over the past--I think since 1994 perhaps, and would probably give you some perspective on our interaction with him.
Mr. COMBEST. Thank you. Before I would start questioning, the Chair would recognize the ranking member of the committee, Mr. Stenholm, if he had any comments that he wished to make.
Mr. STENHOLM. Thank you, Mr. Chairman. In the interest of time, I have a brief statement I'd like inserted into the record.
[The prepared statement of Mr. Stenholm follows:]
PREPARED STATEMENT OF HON. CHARLES W. STENHOLM, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF TEXAS
Mr. Chairman, thank you for holding this hearing today on the EPA's proposed air quality standards. It is appropriate that our committee take a hard look at this issue because these regulations, if implemented, are expected to have a significant impact on agriculture.
All of us are concerned with air quality, and we wan to see strong protections in place to safeguard human health and the environment. By the same token, it is imperative that our Nation's environmental policy be based on sound scientific data. Implementing strict new standards, without adequate cost benefit analysis, could cripple certain sectors of the economy--such as agriculture and small business--and deliver another blow to the viability of rural America.
Given the abundant, safe, affordable food supply that people have become accustomed to here in the United States, it is easy to lose sight of the fact that overburdensome regulation could easily jeopardize our food supply--either through increased cost or scarcity.
Page 17 PREV PAGE TOP OF DOCFianlly, I note with interest that EPA is not here today and hope that maybe in the future we can have them testify before the committee to respond to our questions and concerns about these proposed regulations.
That being said, I am very interested in hearing from our witnesses today, and will welcome any clarification they can offer on agriculture's impact on air quality, and the impact that EPA's proposed standards would have on agriculture.
Mr. STENHOLM. I commend you for holding this hearing. I guess the only observation that I would make is that I would hope after today's hearing that perhaps we might invite EPA to come up also before this committee and to hear their rationale for some of the proposals of which they have made. But today I look forward to this hearing today, and I thank you for holding it.
Mr. COMBEST. I thank the gentleman. That certainly is something we would wish to look at.
I'm sure, Mr. Johnson, there is going to be a number of questions asked. I just want to set a tone of my concerns about this area.
As you have indicated, we are doing much better today than we did years ago. Some of that in agriculture is out of necessity, because there is no option. I have a very highly erodible farm area in my district. It joins Mr. Stenholm's district, and they're very similar. And because of that, there has been some phenomenal technology on conserving both land and water that have come from that area.
It is not all from necessity, however. I think we all recognize and agree that farmers are some of the best conservationists there are. And in making efforts to conserve, there has been a lot of expense, and there has been a lot of reward that has come from those efforts.
And I think we all agree we want clean air and we want clean water. And those people that live in an area are the people who are going to most immediately benefit from efforts that are taken. One of the things that I think is important is that we recognize some flexibility in environmental regulation. There has to be what I call some wiggle room in understanding and in dealing with problems.
Page 18 PREV PAGE TOP OF DOC The example that I continually mention, but I think it highlights what can happen, is the understanding under the Clean Air Act that Lubbock, TX, was declared non-attainment. We don't have industry there that puts smoke into the air, and you can't go out and tell a factory to quit putting out pollutants, because they're not putting out pollutants. The reason of the non-attainment designation was because the dust blows.
Well, that puts you under the same conditions as any other community that has a non-attainment status, and yet there is nothing that community can do about it except live with the huge expense of it. Fortunately, they were able to have that relieved under that standard, but I shudder to think what would have happened if they hadn't had that flexibility to be able to give relief to that community.
And I think it could affect a lot of other communities as well, if we come with a lot more stringent standard that, in fact, we don't believe is based on good science as much as it is based on politics.
There is a point of diminishing returns in which if it is so expensive for a farmer to comply with standards, they lose any incentive to do it, and they walk away from it. Obviously, we don't want to put farmers out of business, but you also then have to look at the consequences of whether our actions that are being taken on a farm, in fact, helping? And what will be the consequences if no actions on those farms were being taken, nobody is out there taking care of them? What kind of problems are we going to incur?
But it's just I guess a statement of hope that as--and this is not as much to you maybe as it is to the bigger question coming from EPA is that there is some logic and some reasonableness in trying to attain clean air and clean water, and whatever we're trying to attain, so that we don't unfairly penalize people who cannot, in fact, have anything to do with the control.
And those things do concern me a great deal. There was a regulation of about 3 or 4 years ago proposed in the Federal Register. Eventually, it was backed away from--but it was under the Clean Air Act--that would have required irrigation wells that are fueled by natural gas, of which there are many of those, and irrigating areas that have natural gas as a potential fuel, to put a monitor on those engines.
Page 19 PREV PAGE TOP OF DOC That monitor would have had nothing to do with controlling the pollution. It just simply would have been a monitor. The estimated cost of that, at that time, was the initial cost of $100,000 per irrigation well, and an annual cost of $25,000 to maintain those.
There are not a lot of farmers in my district who are using natural gas irrigation wells that could afford, for every one of their wells, to outlay $100,000 initially for each of those and $25,000 per year to maintain those. And it did nothing to make for certain that the environment was clean.
The point again being that we have to make for sure that there is an opportunity, as we move forward in this--and it's something I think we're going to be looking at very carefully--to make sure that each individual circumstance can be looked at based upon the merits of its own case, rather than simply a blanket that goes across the Nation and fits everybody the same.
And I recognize that all administration testimony has to go through a central clearinghouse and that it has to make sure you don't have one agency that is competing with another. And I recognize that, to some extent, you are under those constraints. I am not suggesting in that that you are having to hold your punches or pull your punches.
But I would hope that as this issue is pertinent to agriculture that you can not only express the discussions that you have had as a part of the air task force, but as well that you can feel very free to express concerns that you have about the implications that may be long reaching as its effect on agriculture with the EPA proposed standards as they are. And there is no question in that. This initially, again, is just basically some comments I wanted to make.
And before questioning, I would now turn to Mr. Dooley, and we'll do another round.
Mr. DOOLEY. Thank you, Mr. Combest. And along some of those same lines, my focus at this point would be on the EPA proposed regulations, and also some of the interagency comments, some of which were included in an article that was in the Washington Post yesterday, which they identified in the memo from the Agriculture Department that said that the standards are not based on adequate scientific evidence, peer review, and interpretation.
Page 20 PREV PAGE TOP OF DOC There is also another reference to a memo regarding the EPA proposed requirements from the Small Business Administration that said that the proposal is one of the most expensive regulations, if not the most expensive regulation, faced by the small business in 10 or more years.
My concern is that when we have a proposal that certainly is going to have significant impacts financially upon the agriculture sector, and I think that the Small Business Administration's comments would probably certainly apply to agriculture, if not more so to agriculture than any other small business that's out there.
What is USDA doing now to ensure that they are being the voice for agriculture? And are you engaged in any type of peer review or further analysis of the proposed EPA regulations?
Mr. JOHNSON. Let me just comment briefly, first on your comments and on Mr. Combest's, that we certainly agree that over the years, I think we've proven it out that you've got to get these issues resolved at the local level, that there isn't one shoe that fits the whole country, although there may be some standards that we all shoot for.
I think we've got to be more engaged than we have, and that's why the task force is established, and it is active right now. I think that we've got to document the progress that we have made.
And I'd like to, at this time, ask Dr. McClelland to maybe relate to you his experience on the interagency team and where we are, and just hit some of his experience on that.
Mr. MCCLELLAND. Thank you, Chief.
We have been involved for about 3 years now, with an interagency process--that is, involved in review of many of the documents that have been provided through the Science Advisory Committee process, the Clean Air Science Advisory Committee that you may have heard referred to as CASAC.
This includes the criteria document which was the scientific health studies reviews for both ozone and particulate matter, upon which EPA made a determination that there was likely to be health problems caused by some of these pollutants and which ultimately led to them making the health-based proposals that they have for primary standards.
Page 21 PREV PAGE TOP OF DOC After the criteria documents were presented, we also went through and reviewed some documents that EPA calls ''the staff papers.'' And basically, what these are is the EPA taking information from the criteria document, the staff laying it out in sort of a science and policy framework.
In those documents, we were then able to see several of the issues come out that might affect agriculture, and from that point we have been engaged in that process in discussing those issues with EPA.
Following the proposal of these standards, right around last Thanksgiving, we continued the interagency process that had been ongoing and now are meeting on a regular basis to again go over these sorts of issues. And as representatives from the Department, we had been discussing, at the technical level, issues about how agriculture could be affected, and particularly what the costs and benefits of these regulations might be given some areas that the regulations were implemented at some point.
Mr. DOOLEY. I am interested if you could perhaps elaborate a little bit that in your assessment of the EPA proposals. The memo states that you came to the conclusion that they were not based on adequate scientific evidence, and that's a pretty strong statement.
Mr. MCCLELLAND. I think that there might be a little bit of confusion with regard to the memo that you are reading from. In the submission that the Department made to the docket, we submitted a package of technical comments that were made by the Department. That occurred in the interagency process, and we made presentations, each department made a presentation--if they chose to, made a presentation to the interagency group. And then we submitted those written comments to the docket.
Then, there was another piece that was in our package, and this was in response to a letter from Mr. Bliley, that contained the memoranda from the Agriculture Air Quality Task Force to Secretary Glickman, with their recommendations and opinions in it.
Page 22 PREV PAGE TOP OF DOC What you're referring to, I believe, is a statement from the Air Quality Task Force, the advisory committee to the Department, to the Secretary, but not the Department's specific comments that we submitted.
Mr. DOOLEY. Now, did I understand, Mr. Johnson, are you talking about the committee that was just formed?
Mr. JOHNSON. That's right.
Mr. DOOLEY. That just met in March?
Mr. JOHNSON. In March, the first week in March.
Mr. DOOLEY. So the memo that states the concerns on the inadequate science was a memo from that group that they prepared at their first meeting on March 6 and 7?
Mr. JOHNSON. It was a letter that they sent to the Secretary. They had met. They had discussed these issues, and they wanted their concerns expressed to the Secretary. And so they wrote a letter to the Secretary, which is what we've asked them to do, to advise the Secretary on their feelings about these issues. And I think that's what you're referring to there.
Mr. COMBEST. Mr. Lucas.
Mr. LUCAS. Thank you, Mr. Chairman.
And I couldn't help but think, Mr. Johnson, of your introductory comments about the founding of your agency, representing the 6th District of western Oklahoma, which suffered mightily 60 years ago due to the combination of draught and economic depression.
Your agency and your folks are still held in the highest regards by my neighbors out there, as even after 60 years we still work to undo the scars done by events in many instances beyond our control.
Looking to the future, after this interagency decisionmaking process and the task force stuff is all done, could you expand for a moment how you envision, once the final decisions are made and the implementation process begins, what level of participation will USDA be in when it comes time to implement these standards, whatever standards are finally adopted?
Page 23 PREV PAGE TOP OF DOC Mr. JOHNSON. Well, we hope to continue to work together in a voluntary way with private landowners all across the country in meeting any goals that we set as a Nation in this regard. We will also be very engaged in research and in trying to come up with the best appropriate technology that can deal with these issues.
So we certainly hope to remain engaged in this. We don't back away from these kinds of challenges, and we think that the partnership that has worked over the last 60 years can deal with many of these issues.
Mr. Saxton might be able to give you some background as well on where we are on the research on some of this now to be able to deal with it.
Mr. SAXTON. Let me just thank you, Chief Johnson.
I might just summarize very briefly some of the research we've got on way at this point. I'm working in Mr. Nethercutt's area in eastern Washington with something related to the Columbia Plateau wind erosion air quality project, where we have been, let me say, pedaling as fast as we could the last several years trying to stay ahead of the curve and shooting at a moving target with the EPA folks.
We are finding tremendous cooperation with the EPA, with our farmers, with our urban area, but the science is unfolding before us very rapidly, and so the research is very much sort of on the forefront. This is a new area for agriculture in many regards, both in terms of wind erosion, dust from farm implements, the smoke from some of our agricultural operations.
So the research is just on the forefront, and we really are going to have to put some really strong emphasis on this. We've gotten very strong encouragement from our EPA friends that they are very willing and very interested in participating with us as representatives of our agricultural industry.
Mr. JOHNSON. Mr. Lucas, I might add as well that the farm bill gave us a number of tools to work with landowners on these issues--the CRP, both in terms of set-asides of fairly large tracts, but also the opportunity to use vegetative buffers on the landscape to deal with many of the wind erosion issues.
Page 24 PREV PAGE TOP OF DOC The new Equip Program held, depending on what people at the local level really feel they need, I think it would be an excellent tool as well. So we're optimistic that we have many of the tools we need to maintain the technical expertise out there to do it, but we look forward to continuing to work with landowners on these issues.
Mr. LUCAS. Thank you, Mr. Johnson.
Thank you, Mr. Chairman.
Mr. COMBEST. Thank you, Mr. Lucas.
Mr. STENHOLM. Mr. Johnson, you have stated two or three times a statement that I totally concur with, and that is that we'd better work on these issues when we do it at the local level.
And, Dr. McClelland, you mentioned that many of these issues, you've been working on them with EPA for 3 years, interagency task force. Why doesn't EPA concur that working out some of these issues can best be handled at the local level? You don't have to answer that right now. I know the strain that you're in, but that's why I would like to have EPA sitting at the same table with us this morning, and hopefully soon we will have, because we can work out many of these issues if we do it at the local level.
But I'm troubled with another statement in your response both to the chairman and to Mr. Dooley a moment ago, with the work that has been going on in a cooperative way with the task force. The subject--and as you stated a moment ago, your response was to Secretary Glickman--where you specifically challenged the scientific basis of EPA estimates of agriculture impacts.
Now, this is based on USDA's knowledge of research and development. You specifically challenged them in that. What was their response, and how did that find its way, or did it find its way, into the EPA proposed regulations?
Mr. MCCLELLAND. All right. Now, are you referring to our technical comments that we submitted?
Page 25 PREV PAGE TOP OF DOC Mr. STENHOLM. I am referring to the Air Quality Task Force Subcommittee of Mr. Barker, Ferguson, Hurley, et al. The subject is agricultural air quality task force. The date is March 10, 1997, and it is to Secretary Dan Glickman.
Mr. MCCLELLAND. Well, I think that the answer to that is that the task force submitted the memoranda to the Secretary. And in our docket submission, which included the USDA technical comments which were presented at interagency and then submitted to the docket, that the task force letter was also submitted to the docket with the other information that we put in the docket at that time.
Mr. STENHOLM. Now, I'm correct to assume that you're having ongoing discussions with EPA regarding the subject?
Mr. MCCLELLAND. Yes, sir.
Mr. STENHOLM. What has been their response thus far to your concerns as to some of the things they are proposing do not have adequate scientific bases/background behind it?
Mr. MCCLELLAND. Well, let me say two things here. I do not have a personal interpretation of what is meant by scientific peer review, because there are many scientific issues that are being dealt with in this regulation, and some of those are health-based issues which, frankly, I can't really tell you whether or not PM2.5 is bad if you breathe it deep inside your lungs. I don't have an opinion on that.
I think, though, with regard to the science associated with agricultural activities and their production of air pollutants or precursors to air pollution, that we have expressed serious concern about what I believe the chairman was really hitting on the head a minute ago, and that is that agriculture is practiced all over the United States. It is practiced in many different ways.
There are all kinds of different crops. There are all kinds of different husbandry practices. There is different crop mixes. I mean, basically, you name it and we've got it with regard to agriculture. And all of the soil that we're dealing with, and other factors like that, vary not just from the northeast to the southwest but within counties and very small areas.
Page 26 PREV PAGE TOP OF DOC So I think that the issue is one size does not fit all here. And this is so true with agriculture.
Mr. STENHOLM. What has been the receptivity of that statement as you deal with EPA? That is my question.
Mr. MCCLELLAND. I believe that EPA is hearing us on this. I think that we have spent a lot of time talking to them. We are going to continue to spend more time talking with them about this, and I think that when we get into the implementation phase of this whole process that that will really tell us how much cooperation we're getting.
But my opinion is that when I talk to colleagues at EPA, they hear the things that I am saying.
Mr. STENHOLM. I'm asking this in the context--and, Mr. Johnson, you will remember this--we have had some considerable disputes out in west Texas with your agency regarding some of the technical guides that have come from Washington telling us how we can best control soil erosion from wind.
And by listening to the local people and trying some new ideas and relying on some new science that was discovered at the Big Spring ARS station, we found that there were some better ways than what some of the folks in your own agency were telling us we had to do. But it took a little while and discussions before we came around to accepting there may be a better way and we tried it.
And that is the context in which I'm asking the question today, and hopefully we can continue to pursue this because I do think it will work much better if EPA will listen to you a little bit more and be a little bit more common sensical regarding some of the requirements that they sometimes get blamed for. And that is the context in which I was asking the question to you today.
Mr. MCCLELLAND. If I could just follow up with you on that a little bit. I think that as the chief mentioned a while ago, I think the one thing that EPA really does listen to is peer reviewed science. If you look at the health research side, whether or not we agree with what their conclusions about that are, those are all peer reviewed studies.
Page 27 PREV PAGE TOP OF DOC I think that the important thing here is that we need peer reviewed research. Dr. Saxton has indicated some of the stuff that USDA, through the Agricultural Research Service and the land grant system, has been involved in. I believe you're going to have some gentlemen on the panel following us who are going to talk about their research projects.
And that's what is really important--how research in Texas really relates to implementation of regulations, of rules in Texas that might move towards meeting some kind of an air quality standard.
Is agriculture causing a problem? We need to find that out. If it is, then what are the cost effective ways of controlling that problem? And it may be something that is very simple to fix. It may not be a problem at all, and I think that that is where we need the peer review research program to really answer those questions.
Mr. JOHNSON. Mr. Stenholm, in the Air Quality Task Force we have a member of that task force from EPA, and I know that there was a very good feeling in that two-day discussion that we had opened a very large door and were communicating probably better than we had before on these issues.
And George Bluhm has been working with EPA fairly closely on this, too, and he may want to comment on that.
But I think, in answer to your question, we are getting engaged, and I think that we intend to make sure that the good science in agriculture is heard, and that we work together with EPA on this rather than having people do things to us.
Mr. BLUHM. Thank you, Chief.
I have represented agriculture for about 2 years on their FACA, along with members from the Forest Service, and I'd say that we have had an opportunity to get into discussions. And one of the areas where they have looked to us for leadership is in the scientific area of prescribed burning. And we have been engaged much more there than we have in the rest of the areas.
Page 28 PREV PAGE TOP OF DOC There are two things that I'd like to lay on the table just for information's sake. A lot of times when we say science and they say science, we are talking about two different sciences. The scientific community that EPA tends to lean on is a medical scientific and health science or fields. And that is what they mean when they say science.
Whereas, when we're talking about it, we talk about the science basically for the impacts on agriculture, and that is a science that a lot of our people in USDA tend to think of when we talk about science. EPA's authority is to look at the health impacts, and so they tend to rely on medical science.
That was one thing. The other thing that I would like to talk about goes on in the PM specialty area, remember that particulate matter is measured by mass and that a 2.5 particulate matter is a part of the PM10 particulate matter. Those are definitions, and that's all. Just remember that they are part of it.
Getting back to how we are being engaged, we are definitely being listened to. I can say that much. We do have opportunities to voice, but their FACA system--they have over 60 members and they're expanding to probably 90. That's a guess. And with that many people around the table, and with several subcommittees, there is an awful lot of information that is generated meeting to meeting.
Mr. COMBEST. I would hope this engagement leads to a marriage, and that while they may be looking at the health aspects of it, and we're all concerned about health, obviously we're glad you all are involved, because you should be looking at it from the agricultural aspects, and the cost benefit of it, and whether some of the recommendations may actually exacerbate the problem.
Mr. COOKSEY. Mr. Johnson, let me ask you just briefly, I was looking through the CVs on some of the panels after you and they are big-tailed. What is your scientific background, or what is your background?
Page 29 PREV PAGE TOP OF DOC Mr. JOHNSON. I have a bachelor's and a master's degree in forest ecology and have done some Ph.D. work. I also have farmed for about 25 years, which is a good education.
Mr. COOKSEY. Dr. McClelland, question. You said that pollutants cause health problems. What pollutants? What health problems?
Mr. MCCLELLAND. Well, what I said was that some pollutants may cause health problems. I personally don't know. I'm not a physician.
What these proposals are aimed at are PM2.5, particulate matter that is smaller than 2.5 microns, really quite small.
Mr. COOKSEY. Give an example of that.
Mr. MCCLELLAND. An example of that? Well, combustion products from a diesel engine, for example, or from a gasoline engine, or combustion products from a coal-fired power plant. These particles could be----
Mr. COOKSEY. In the agricultural field. What would a farm----
Mr. MCCLELLAND. Well, I think Mr. Saxton would be a better one to answer the question about what agriculture might produce.
Mr. COOKSEY. Well, the reason I ask, you made the statement, and I just wanted to get a little more explanation on your statement.
Mr. MCCLELLAND. Well, I think that the documents that EPA has presented that look at a number of peer reviewed studies suggest that particulate matter, particularly the small PM2.5, may cause health problems. I believe that their number in the risk assessment, which has been recently revised, suggests that there may be as many as 15,000 premature deaths every year from----
Mr. COOKSEY. To farmers?
Mr. MCCLELLAND. No, for the population in general, for the population of the United States, that there may be 15,000 premature deaths every year. That is the information that----
Page 30 PREV PAGE TOP OF DOC Mr. COOKSEY. I'm not questioning that. Is there concern--I understood there is concern in California about harvesting crops, and particulate matter from that standpoint. Is that true? Is that one of your particulate matters that you're concerned about?
I'm talking about crops that cause some dust. I have bailed hay on my farm, too, Mr. Johnson, and there is some dust. And we do it in the hot summer.
But go ahead.
Mr. MCCLELLAND. That could be an activity that generates particulate matter. But whether or not that's the particulate matter that is of concern is something that I don't know. I am not qualified to tell you about that. I think that Dr. Saxton could tell you about that.
Mr. COOKSEY. What is your Ph.D. in?
Mr. MCCLELLAND. Economics.
Mr. COOKSEY. I see. I'm a physician, so that's the reason I'm concerned about health. And I'm not trying to make you honest, but, you know, if you make a statement, I just wanted some details.
Go ahead, Dr. Saxton.
Mr. SAXTON. Could I just perhaps use Mr. Nethercutt's hometown, Spokane, WA, as an example of a non-compliant city that has been very aggressive in looking at their source of pollutants, and they have identified any number of them. For example, unpaved roads will generate dust of these particle sizes.
They have sanding materials that they put out in the wintertime that develop some dust in them. They have wood smoke from fireplaces. Those are all within the city limits, and they are working very aggressively to minimize those, and they have done that.
Then, there are outside----
Mr. COOKSEY. These are farmers within the city limits?
Mr. SAXTON. No. These are urban sources within the city limits that, in fact, they are very aggressively working to reduce the number of those particulates. They have spent several million dollars on additional street-sweeping equipment, for example.
Page 31 PREV PAGE TOP OF DOC Then, there is outside sources, such as burning by farmers on their grass fields, and then there is the wind-blown dust in our region, and this is kind of typical across the dry western part of all of the United States, that wind erosion will cause soil materials to be entrained. These particulates are so small that they--well, for example, a PM10, you can lay about seven of those side by side and make about the diameter of a human hair. This will put it in a little bit of perspective. 2.5 is a quarter of that yet.
So these are so small that they are not visible. They get entrained in the air mass, and they become airborne and almost no opportunity to precipitate out except by rainfall and other cleansing agents.
So there are multiple sources. Agriculture is an emission of some of them.
Mr. COOKSEY. Well, in closing, Mr. Chairman, I have a feeling that sometimes the EPA is trying to hammer farmers, and I'm from a district that is--and the basis of our economy is agriculture. And I am concerned that there are people that don't have scientific backgrounds that are rendering scientific opinions, or throwing out something that they don't know what they're talking about.
I have this photograph, and there has been some concern about emissions from cattle, gas emissions, and the next thing they're going to be concerned about is gas emissions from homosapiens. And I think that's when it's carried a little bit too far.
I happened to have an EPA person in my office one day making a courtesy call, and I asked her, I said, ''Well, what is your scientific background, or what is your background?'' She squirmed a little bit and finally said she did not have a college degree, but she has been in Government for a long time, basically been a regulator.
And I am from the private sector, and we resent these people that come in as regulators that don't have the background to do what they claim to be doing. And I get the feeling about this in this department, too.
Page 32 PREV PAGE TOP OF DOC Thank you, Mr. Chairman.
Mr. COMBEST. Thank you, Dr. Cooksey.
Mr. BERRY. Thank you, Mr. Chairman.
I want to welcome my former colleagues from the Department, and I recall a lot of work that we've done together and am very proud of what we accomplished together when I was there. And I also recognize the great work that the NRCS does and has done for this country and continues to do.
One thing, Chief Johnson, that you mentioned that particularly struck me in your testimony was the environmental budget. And it is a concern that I have had for many years, ever since we began to basically regulate landowners in an attempt to improve the environment in this country.
As we impose these standards, whether it be Endangered Species Act or wetlands or air quality, or whatever they are, it seems to me that rather than it being paid for like other things for the common good, that the landowners get the bulk of the burden of these budgets.
And I don't think that's fair, and I don't think we're going to be able to solve these problems with any degree of comfort until we recognize that and come up with some way when these standards have to be implemented that everyone helps pay for them and not just the burden be placed on the landowner. And I would be interested in your thoughts about that.
Mr. JOHNSON. Mr. Berry, I couldn't agree with you more. And, in fact, we do know across the country that private landowners and farmers are willing to contribute a great deal. And I think if we were to really tally it up, we would find that they are contributing far more than even they think they are to this.
We set out 60 years ago to partner together with private landowners. And as I said, we contributed a great deal of financial and technical assistance to doing so. I believe the will is still there to do it. A couple of years ago we went out with a Gallup poll across the country to ask Americans what they thought of a number of industries, agriculture being one, and how they related that to stewardship of our natural resources.
Page 33 PREV PAGE TOP OF DOC Although we didn't hit 100 percent, I'm proud to say that Americans still feel very good, or they feel very strongly about the fact that agriculture is trying to deal with these issues. And in other questions that we asked them, it was very clear that society was willing to contribute very significantly to this.
I think as we work through these issues, we'll continue to try to be able to see if we can't draw that line and say farmers will contribute. But where it costs farmers to do so, and they can't recover those costs, then society has a responsibility to work together with them.
We'll do everything we can to continue to make that message clear. The Geography of Hope publication that I mentioned earlier is a statement to that regard, that we agreed to this partnership many years ago. It has worked, look at the progress that has been made, and that we think that that is the best way to continue, whether it be air quality, water quality, wildlife habitat, you name it. This partnership works.
Mr. BERRY. I am also interested--do you think that the Department of Agriculture has the necessary scientific data that they will need to come to a successful conclusion in negotiation of these standards?
Mr. JOHNSON. I think science is an immense journey that will continue and we'll never have all of the answers. I think it's important as we look at the research title, though, that we pay attention to it, and we certainly continue to support that. But I think Dr. Saxton could probably give you a better answer to that question, if you'd let him try.
Mr. SAXTON. Well, just a thumbnail sketch to give a little bit of perspective of where research has come from on this particular issue of particulates. This is a new area for us in the agricultural area in particular. And it has only been in the late eighties that even the PM10 standard was suggested and adopted by EPA. It was only about 1990 then that the Air Quality Act was put into place.
This was the standards that were put into place, and then we, in the agricultural sector, needed to learn how to measure, how to adopt, and how to identify agricultural impact on these standards, and contrary, how these standards and the particulates impact our agricultural industry.
Page 34 PREV PAGE TOP OF DOC So it is a new science, and we are, as I mentioned before, pedaling as fast as we could. There is a number of areas in USDA/ARS, my own research area in Washington, one in Texas, the Big Spring station was mentioned earlier--very active in this area--and our Manhattan, KS.
This is the only focused research efforts that we have ongoing at this time, and it is a minimal effort, and we really need to, I think, be very aware that this is an area that needs expansion. We're going to have to develop this scientific base in order to be able to work effectively with people like the EPA and our constituents, wherever they are, within the agriculture industry. Because as we've said, it is quite a variable industry, and local issues will have to be worked out, but we need some good sound principles to help them with.
Mr. BERRY. I am also reminded of the great difficulties we've had dealing with wetlands regulations in this country. And I've always felt like that the NRCS is the best equipped to make those decisions and deal with that problem at the local level, like the ranking member has already mentioned.
And I'm curious as to whether or not you have a formal agreement with EPA or anticipate one as far as the Department of Agriculture's role or NRCS's role in the implementation of these standards.
Mr. JOHNSON. As far as I know, we don't have one now, but it certainly is going to be on the table as we work through this. We're willing to accept our responsibility to work with private landowners on these issues, and we'd urge you not to put us in a regulatory role in doing so.
Mr. BERRY. That's all I have, Mr. Chairman.
Mr. COMBEST. Thank you.
Mr. Johnson and Dr. Saxton, I'd say this subcommittee also has a research title, and I assure you these will be very important.
Page 35 PREV PAGE TOP OF DOC Mr. LEWIS. Yes. I just want to follow up on what Mr. Berry was asking there. Dr. Saxton, is there a model in place or one that you are working on to determine the PM emissions, their source, and something that would hopefully be more accurate than what the EPA has put forth?
Mr. SAXTON. Yes. Let me answer that in maybe two or three different approaches, because there are two or three major particulate emission sources that we're dealing with. The one that we're most focused on right now is particulate emissions by wind erosion. When large wind erosion events occur, not only are we losing the resource from the farm land, but we are emitting particulates from that soil material.
And we're just on the very front edge of developing an estimating routine that we hope EPA will acknowledge as good science. This is a cooperative effort, again, amongst my own research, that in Texas, and that in Kansas, and so it is a USDA effort.
There is another major source that impacts other areas in terms of emissions from farming and harvesting operations that we're concerned about. We have only touched on some of that science. I think you'll hear from some of the other scientists today in your hearing that there is some historic data there. But it probably is not quite pertinent to today's standards, because we're changing. We've gone from total particulates to PM10 and talking about 2.5, you see, so it's a bit of a moving target there.
There are other particulates, particularly in the smoke issues, grass burning, residue burning, other sorts of burning that cause these smoke particulates. There is not a lot of research I'm aware of there, but that's not quite my particular research area. So there is a number of facets ongoing. We really can't lay one on the table and say, ''This is the total answer today.'' It's got to come through additional research.
Mr. LEWIS. Thank you.
Mr. COMBEST. Thank you, Mr. Lewis.
Page 36 PREV PAGE TOP OF DOC Mr. JOHN. Thank you, Mr. Combest.
I have a couple of comments I want to make and end with a question. These proposed regulations are of grave concern to myself and my constituents being in southwest Louisiana. That's where my district is. It's an agricultural district, but it also has a major presence of petrochemical industry.
In fact, one of the parishes just 2 weeks ago became--was in a non-attainment area and became out of that status just a couple of weeks ago. So we've been working for 8 years to get there, and now we're looking at possibly becoming back 8 years of where we have gone.
But I guess my concerns are, you know, even within the EPA, there is a lack of consensus amongst their scientists that this is about--the proposed regulations are going to help. I think we must keep in sight that what we're trying to do here is make sure that the health benefits are there.
We must never ever lose sight of that, and I think that the only way that we can get to those, to that end, is to make sure that we have the good science that is in place. And that's my comment.
Specifically, some questions--Mr. Saxton, you had mentioned in your comments to Mr. Lewis just recently--and this is what concerns me. You talked about the PM sources. You talked about wind erosion. In your own words, you said, ''We are just in the front edge of looking into that.'' You talked about emissions from farming operations.
You said that it's not quite pertinent, and you also talked about smokes and grass burning. You said there is not a lot of research. Those are the kind of statements and concerns that I had as to should we move forward, because when you look at my district, which is farming based, but on the edge of petrochemical, it's meshed and it's intertwined. And I think that it's going to have a substantial negative impact on my farming community.
So I want to make sure that you guys at the table, and ladies, are a part of this process. I guess do you feel like you have been a part of this process first? Will you continue to be a part of this process, and not just a facade or just for comments? A real integral part of this, because I think it's not only to the farming community, but this takes a wide brush and brushes across many, many industries other than just farming in this country.
Page 37 PREV PAGE TOP OF DOC Mr. JOHNSON. Well, I think that we're very rapidly becoming a very important part of it. I have confidence that we're at the table. Through the task force and through the interagency group, we are bringing good science and expertise that we do have to it. So I certainly feel that we are at the table, and we're going to be part of the process from this point forward at least.
In terms of your comments on if we don't have the good science, then we should hold back, I think that--and maybe that's an unfair paraphrasing of your comment--we do know that we have a lot of opportunities to continue to make progress. There is a lot of low-hanging fruit out there, if you will, win-win situations such as residue management, and things like that.
So many of the things that we're doing that make good sense from a general conservation standpoint also move us in the right direction when it deals with these things while we're waiting on better science. We believe that we need the good science, and we'll continue to work on it. But that should not mean that we shouldn't continue to move to do good conservation on the land.
We think there are many things that farmers are doing and will continue to do, and the new programs that you've given us give us the opportunity to do so. That will continue to improve air quality, even without having the absolute answer to many of these questions.
Mr. JOHN. Right. Well, I certainly didn't suggest that we ought to stop striving to clean our air. I just want to make sure that the cost-benefit analysis of this whole situation--and to keep in main focus that we're doing it for health benefits, and not as a policy decision just because we want to do this, because it has some very serious economic impacts on a lot of industry. And we must, I believe, move slowly but also making sure that we are right on the mark as we move towards striving for that clean air, which I want to be a part of. Thank you.
Mr. JOHNSON. I agree with you, but I really want us in agriculture to take credit for the good work that is going on as well. Sometimes we dwell on the bad side of it. We've got to address the bad side of it. But there is terrific progress out there, and I urge us all to be thankful to farmers and ranchers across this country for the good work that they are doing already.
Page 38 PREV PAGE TOP OF DOC Mr. JOHN. Right. And my hat's off to Mr. Combest for having this, because I believe that this is going to launch a whole level of negotiations with this whole matter from an agricultural standpoint, and I believe that today is a good indication of that. Thanks.
Mr. MCCLELLAND. Mr. John, if I could just follow up with you for a moment there, because I think that you brought out something extremely important when you talked about what your district looks like. You have petrochemical. You have agriculture. And I think that the real issue when you get right down to your district is--let's assume for a moment that your district does go into some level of non-attainment for whatever reason for the implementation.
I think that the real question about fairness here, which is I think what you're getting at, who is responsible for what? And with many stationary sources, it seems to be easier--for instance, like your petrochemical plants--to get a handle on what kind of emissions are coming from those plants. And, of course, EPA and, you know, the public has been concerned about a number of those things for a long time, and they have looked at those industries. I think they know a lot, for example, about power plants, coal-fired power plants, and what not.
What we don't know are those kinds of things about agriculture, and we don't know those kinds of things about agriculture in your district and in your area. And I think that that's really the point, what is the apportionment of sources here to the total amount of emissions that we have in an area?
And that is really the tough question here, and I think the question that--we're working to try to make sure that EPA understands that we need to develop that kind of information, and often times on a very local basis.
Mr. JOHN. I think that's a very, very good point. It is relatively easy to monitor the stationary situations that you had spoke of. But in an agricultural sense, we need to be very careful that we don't get caught in the whole net and get our share, our undivided share of the responsibility when, in fact, we are not part of that. Thanks.
Page 39 PREV PAGE TOP OF DOC Mr. COMBEST. Thank you, Mr. John.
Mr. NETHERCUTT. Thank you, Mr. Chairman.
Gentlemen, welcome, especially Dr. Saxton. Nice to see you here, sir, from my district. And I appreciate all of the very good research that is being done with PM10 at Washington State University.
Just a quick couple of comments, and then I want to focus on two areas that I'll allow you to certainly answer and am anxious to have your answers to the questions.
The comment has been made about coordination between agencies. And I think that is extremely important. We're seeing it in our State, Dr. Saxton. As you know, the State Department of Ecology has imposed a ban on burning of agriculture, particularly grasslands, bluegrass fields, to be implemented over time.
And I noticed in the Appropriations Committee work that I am doing with--we had Secretary Babbitt appear before us to talk to Mr. Bluhm about prescribed burning. At a time when the EPA is considering a 2.5 standard, to have the Federal Government come in in lieu of extraction to do prescribed burning, didn't seem to me to make sense. It's not very well coordinated, notwithstanding the potential good science that comes from prescribed burning in some areas.
But nevertheless, we are faced in the State of Washington with not only this burn ban but potentially an EPA standard that is going to be very difficult to meet. And Spokane is aggressively working on trying to meet the PM10 standard.
So my question--two questions, two areas go this direction. Number 1, Dr. Saxton, Mr. Johnson, we put in more research money I think every single year. My predecessor supported it. People in the Senate supported PM10 research. I just signed a letter last week to go to Chairman Skeen asking for more PM10 research.
Page 40 PREV PAGE TOP OF DOC The question is, and maybe it's an easy answer for you, is the research money that has been presented for use by your agency adequate? Would more money allow faster research and possible potential solutions to this problem? You can handle that one, and then I want to talk about CRP for just a minute.
Mr. SAXTON. Well, I suppose the answer is fairly obvious. [Laughter.]
But you have to be a little bit careful that----
Mr. JOHNSON. They've got plenty of money. [Laughter.]
Mr. SAXTON. The question is, if we threw more money at it, would we get an answer faster? Undoubtedly, yes. We are just struggling along to get the project off the ground. We have a very active research group focused at Washington State University.
We are almost totally by ourselves in the scientific domain. There absolutely has to be more research in other areas. We've got other focus areas besides Washington State. We could use some additional impetus there as well. California has similar problems, but different sources. It's a different problem there.
We really are going to have to emphasize more research that has to do with their kinds of problems as well. We have other problems that we're not even addressing, such as the smoke issue, which you raised very appropriately. And we have almost very limited scientific data to back that up. That's a bit of the reason we're seeing I think some what we think is unreasonable regulations without the science behind it. We haven't been able to focus some research on that area.
So let me just say in summary, there is a number of other air quality issues out there in addition to the wind erosion area that we have addressed that really we've got to get our teeth into and fairly quickly as we see the whole air quality issue unfolding on us fairly rapidly.
Mr. NETHERCUTT. Thank you. And I assume this committee will grant appropriate authorization, and certainly the Appropriations Committee, if I have anything to say about it, will grant appropriate funding to assist in helping not only the Pacific Northwest but all areas of the country that have to deal with the wind erosion and particulate matter problems. Make sure you have enough money to do the job.
Page 41 PREV PAGE TOP OF DOC The second thing is, with regard to CRP, I look at this conservation reserve program as an effective way to deal with particulate matter problems in the northwest and elsewhere in the country.
Under the farm bill that was passed last Congress, there are some new rules, some new enrollment equations, and we worked hard to get wind as a higher factor in determining eligibility for enrollment.
Two questions to Chief Johnson and any others on the panel that want to answer it. Number 1, are you concerned about any limitations on CRP enrollments under the new standards? And second of all, can we conclude that a limitation on CRP enrollments will cause consequences in negative air quality standards? In other words, if you don't have as many CRP acres enrolled, will there likely be more problems with air quality as a result of that limitation on enrollment?
Mr. JOHNSON. Certainly, the answer to your last question is yes. If we don't farm, we won't have as much wind erosion as if we farm. So the more we can put into CRP the less we'll have. But that should not be the real question. The question should be whether or not we're focusing the CRP as best we can to deal with air quality issues as well as wildlife, soil erosion, water quality issues, and so on.
And I think at this point, the Department is waiting to get the results of the numbers that we have in on the kind of benefits we're receiving before we say whether or not there should be 25 million acres or 20 million or 15 million acres enrolled. So I think there is a general feeling that we've got to get the data before we can say that there is--you know, this is what ought to be enrolled or not.
As we've gone through this process this time, and trying to look at air quality as being one of the issues in how we develop environment benefit indices, I think we've come to the conclusion already that we're going to put a lot more effort into that arena, to see how we can use a program like CRP better to do that.
Page 42 PREV PAGE TOP OF DOC And this gets at pushing the research and our understanding of how we can utilize these programs to get greater benefits.
Mr. NETHERCUTT. Well, that's great.
Again, Mr. Chairman, we'll do our best from the appropriations side to fund you adequately, and make sure that the Nation is benefitted and the air quality of the country is benefitted by virtue of having the research tools necessary to meet the problem. So I thank the chairman.
Mr. COMBEST. We will try to give you ample opportunity to fully fund this. [Laughter.]
Mr. JOHNSON. Technical assistance is a very important part of that as well. [Laughter.]
Mrs. CLAYTON. Thank you, Mr. Combest, for having the hearing. I was going to comment on Mr. Nethercutt's comment about appropriations--how lucky we are to have someone on appropriations who is willing to find an opportunity to fund those things that we advocate here in agriculture.
I think one of the things I'm struck by in this discussion and this hearing is that we're one day after the day of Earth Day, and we're talking about a formidable act--it's called the Clean Air Act--which drew this into some focus. And how America has come to the realization that no longer are we debating whether we should have clean air or environment. We have come, as a country, realizing that it is imperative that we have clean air and water.
But we also, I think, have come to it as a matter of conscience and reality that we have to find reasonable ways and understandable ways of achieving that. And so the issue of the new standards that are now being promulgated by EPA, the difference in how we go from a 10 to a 2.5, or whatever the new proposal is, is a point of tension, not the point that we don't want anything out here that gives asthma, will give farmers lung problems later on. It is, how do we achieve that back home? It simply means, who is having to pay for it.
Page 43 PREV PAGE TOP OF DOC I do think there has to be some realization that the country has come to the point that we no longer argue whether we ought to have clean air. And so the issue is, how do we have the best science together determining the standards?
But that's not to negate the value or once you want to implement it, you are implementing on the blank page or, rather, the dusts or, rather, the emissions from certain farming activity is actually the cause of that.
So in some ways we've got to find a way I think in this committee and particularly the research component, which is not yet complete, to make sure that we just don't rush at it but we go carefully at it to make sure who is causing this. So if we want to implement a cleaning there, we have to find out actually the source of it.
And I'm struck by the next panel's comment is that this has a whole new dimensional order, these such articles. And Mr. Combest can cause it in Texas, and it can go over in Arkansas. So pretty soon Arkansas is having to monitor it.
So this is interrelated. I think if anything makes us recognize that the interdependency of environment but also interdependency of farming and with people. We're not going to stop farming. So we need to find out how we farm in the most efficient way.
And I guess mine is more of a comment than a question, but I would I guess finally ask you, Mr. Johnson, since you have the responsibility for this, as to what you see that you can do to assist not only EPA in understanding the farmers' effort to try to clean, get their act in place consistent with their standards. I contend that most farmers I know won't clean.
I don't focus on the tension between it. I focus that most people want to live in a healthy society, want their kids to live in a healthy society. And we have come to appreciate that.
But what is it that you can do to either help EPA to understand what measures farmers are already taking and how they can further implement if given time and tools? And, second, is there a way for you as an agency to be engaged in the standard-setting? Apparently you were not the last time around.
Page 44 PREV PAGE TOP OF DOC Mr. JOHNSON. Well, we've mentioned some of the attempts to do so. The task force is one. We have been engaged in an interagency effort. And I suspect that that's going to be increased even.
Within our own agency, we have I believe in every EPA region a person from agriculture, from our agency, in fact, assigned to those regional offices with the intention of them being able to be plugged in all the time at the field level with EPA so that they understand the agriculture industry and the private land sector and how we can deal with this.
It's probably important that we maybe even increase that understanding. And I would like to see EPA and other agencies do the same with us, assign people to us so that we can have this dialogue going much better than we have in the past.
I think you're right, and I certainly agree with you, that we all want clean air and that as we set these standards, one of the major questions is who holds what responsibility for achieving them.
In our Economic Research Service, we're certainly going to be engaged in that to try to partition responsibility and figure out ways in which we can assist people in doing this.
You know, if a power plant, electric-generating power plant, is found to be out of compliance, they can come back into compliance, but it's--I shouldn't say it's easy. They would say it's not easy. But they can pass some of those costs on to the consumer.
It's much more difficult for an individual farmer or even the farming community to be able to do that. And I think that we're certainly going to raise that dialogue to a national one with EPA and with others to figure out ways in which we can assist landowners to continue to improve in this arena. But we are engaged, and we're going to be more engaged in these efforts.
Air quality we have been talking about forever. When we talk as an agency, we talk about soil, water, air, wildlife. These are issues that we always talk about. Air is always sort of thrown in or it has been in the past. I don't think it will be the same from this point on. I think it's something that we're going to pay a lot more attention to in the agriculture community.
Page 45 PREV PAGE TOP OF DOC Mr. COMBEST. Mr. Schaffer.
Mr. SCHAFFER. Thank you, Mr. Chairman.
I've got a number of questions. With respect to the Department of Agriculture and your involvement in the air quality task force, I just want to know, does the Department of Agriculture support the 2.5-micron proposal that the EPA is putting forward?
Mr. JOHNSON. Would you like to answer that question? You're close to it.
Mr. MCCLELLAND. Thanks. Well, I think that where we are right now with that is that we're in an interagency process. And we have been continuing to review every aspect of the EPA proposals in the interagency process during the comment period. And, actually, we are now part of the rulemaking.
So I think it would be inappropriate for me to respond directly except to say that we are in the interagency process, we are actively involved, and we are continuing to review every aspect of the proposals with EPA and other agencies.
Mr. SCHAFFER. The EPA has gone through the same process that you have, it sounds like. They have an opinion on 2.5. They tend to favor it. And I am just curious. Within the Clinton administration and this agency's role in it, do you concur with where the EPA is headed or is there any opposition at all at this point?
Mr. JOHNSON. I think this gets to the point that Mr. Cooksey was making earlier. And the point that I hope isn't lost here is that USDA is not a health agency.
We don't have the expertise to make judgments about health aspects. Those judgments are being made by the professionals at EPA and by professionals in other health agencies in the Federal Government.
What we are concerned with is what the potential effects of any of the proposals could be on the agriculture sector and how those effects are assessed and----
Mr. SCHAFFER. So what I hear is that the role of this panel is more reactionary than proactive with respect to these air quality standards. Is that correct, a fair characterization?
Page 46 PREV PAGE TOP OF DOC Mr. JOHNSON. I think that's a fair characterization inasmuch as we are not standard setters, no.
Mr. SCHAFFER. Understood. Let me ask, then, about the Forest Service. As Representative Nethercutt has mentioned and others perhaps, the Forest Service has decided that it is a good idea to increase the number of prescribed burns within the country. Does this panel have a position on that topic?
Mr. JOHNSON. I think the best answer to that and to the previous question is that we've got to lay on the table good ecological science, good management tools together with health standards that----
Mr. SCHAFFER. Let me interrupt. Let me try it a different way. Has this panel reached a conclusion as to whether the prescribed burns are in the best interest of agriculture or contrary to the agricultural goals in the United States?
Mr. JOHNSON. I don't think the panel has come up and said this is the only answer to this issue. I think that we're in the process in the panel. The task force is certainly trying to raise the issues and have a good healthy debate about it. We feel that we haven't had the opportunity to do that.
Mr. SCHAFFER. So, just to be clear, you have no conclusions on the prescribed burns at the present time?
Mr. JOHNSON. I'd have to say I don't know for sure.
Mr. SCHAFFER. The EPA has come to the conclusion that 40,000 premature deaths in the United States can be attributed to particulates. Within the context of this panel and its role in assessing these new standards, do you accept those numbers as a basis for your discussions and considerations or has that estimate been challenged in any way by your review?
Mr. MCCLELLAND. Well, I think that that estimate has actually been changed based on some new information that EPA obtained. And it's been reduced somewhat. I believe the number that I was briefed on was 15,000.
Page 47 PREV PAGE TOP OF DOC Mr. SCHAFFER. They say that under the proposed new particulate standards, that the 40,000 number, claims the EPA, could be reduced by 15,000. You could save 15,000 lives by going to 2.5, they say.
Mr. MCCLELLAND. Well-put, sir. Again, here with regard to this, where that information comes to play is as we move into the phase of looking at the costs and benefits of this regulation, this is a bit distasteful, but the costs of those lives, the productivity of those lives, which is again not something that our economics group works with, but we have been interested in that methodology and in discussing that methodology, but we have not per se been deeply involved in that discussion.
Mr. SCHAFFER. One last question. I see my time is running out. This is to Mr. Johnson. The comment about the CRP Program and the rules that the Department of Agriculture has proposed, which, in fact, broaden the eligibility and expand it beyond just highly erodible land from wind and soil erosion to other types of environmental objectives, is of great concern. I heard your comments that acknowledge that, but I'd like to ask a question with regard to a specific proposal.
The Clinton administration has suggested moving $65 million out of the CRP Program toward the purchase of the Crown Butte mine in Montana. Do you see any way that that helps our concern about particulate matter within the context of the CRP Program?
Mr. JOHNSON. I think the administration is recommending that there may be carryover in CRP and that they're looking for ways in which they can find money to do that.
I would rather not get into a conversation with you. I don't think it's appropriate for me. I don't have the authority to carry on a conversation with you on that.
Mr. SCHAFFER. Why isn't it appropriate? This is the panel that renders an opinion as to the effect of these decisions on agriculture. This is moving funds away from an agriculture program designed to maintain and protect land from soil erosion, which is what's going to be regulated here.
Page 48 PREV PAGE TOP OF DOC And I guess that is what I'm asking you to comment on, whether moving $65 million out of the CRP Program helps agriculture or hurts agriculture with respect to the regulatory consequences on air quality.
Mr. JOHNSON. As my introductory comments referred to, I believe that we don't have anywhere near the resources in the private sector or in conservation on private lands the way it is right now. We are not balancing our conservation budgets on private lands.
And I would urge us all to continue to take a look at this and see how we can have more resources in private lands, not less.
Mr. SCHAFFER. I'm testing the chairman's patience, but I would just urge you to communicate that sentiment to the President if possible.
Mr. JOHNSON. Certainly. May I make a comment on the medical side of it? We do on the task force have two medical doctors. And we had a number of very good discussions on the health impacts.
I think that we have decided in the task force, though, that we are not a health task force. We have them there to make sure that they are fully engaged on these issues as we deal with them. But we're doing our best to look at them from the standpoint of both the economic and the technical side of it and how we can deal with these issues waiting for the final decision of whether or not there are so many deaths or not related to these air quality issues.
So we certainly have people engaged in it, and they're bringing some very good wisdom to that panel.
Mr. SCHAFFER. Thank you, Mr. Chairman.
Mr. COMBEST. Actually, the Chair was rather pleased with the gentleman's questioning.
Mrs. CHENOWETH. Thank you, Mr. Chairman.
I'd like to know what the scientific basis is for the implementation of these new rules and regulations. I know that we're talking about changes in the culture and all kinds of things, but what is the scientific basis for this?
Page 49 PREV PAGE TOP OF DOC And, No. 2, was it ordered by the court? Has there been a court order? Has there been any harm proven? Mr. Johnson?
Mr. JOHNSON. Certainly the scientific basis I'd like to pass on to our agriculture researchers, our Mr. Saxton, to maybe respond to that.
Mrs. CHENOWETH. Before I let you go, let me ask you the second part of my question, then. Has there been a court order which through the court system they would have determined that there was harm? Has there been a court order that prompted these more restrictive guidelines and regulations?
Mr. JOHNSON. Mr. McClelland is begging to answer that question.
Mr. MCCLELLAND. Only because I think I have a reasonable answer for you. The particulate matter standards are being issued under court order. A suit was brought. And I have to confess I can't remember the dates for all of this, but a suit was brought by the American Lung Association.
The court did order EPA to promulgate the proposals by I believe November 29. And I think that Mrs. Browner went forward with them the day before Thanksgiving, which was a few days before that deadline.
They required a final rule to be promulgated I believe by about June 18. There was an extension of the comment period by about 3 weeks because of many requests from the public to extend the comment period to allow the public additional time to get comments into the docket. And so there was an extension of the comment period.
And subsequently the judge in the case also extended the deadline for final promulgation of the standards by the same amount. So I think the drop-dead date here is July 18.
You could check with EPA, but that's essentially what's happened here.
Mrs. CHENOWETH. Would you mind providing at least the name and the cite on that decision? And was there a finding of harm?
Page 50 PREV PAGE TOP OF DOC Mr. MCCLELLAND. Maybe George can help with that.
Mr. BLUHM. It's my understanding that the court order was simply to review the process, that there was not an edict that a new standard had to be legally issued. It was a review requirement.
Mrs. CHENOWETH. So there was not a finding of harm?
Mr. BLUHM. I do not believe so, but I'm not an expert either.
Mrs. CHENOWETH. Would you mind providing the name and the cite through the committee so I can be sure and get that? You'll try?
Mr. BLUHM. Yes.
Mrs. CHENOWETH. If you're not able to succeed in that, would you let me know what the problem is? And we'll try to look for it.
Mr. BLUHM. Certainly.
Mrs. CHENOWETH. Mr. Johnson, I interrupted your answer. Please.
Mr. JOHNSON. I think Mr. Saxton was going to take the next question, the one dealing with the science.
Mr. SAXTON. Mrs. Chenoweth, as a researcher 8 miles from your district in Pullman, WA I welcome that question. We are not in the process of dealing with the health issues, which are the driving factor about the standards. But we are very aware of them.
There were a number of scientific articles published in the National publication of the Air and Waste Management Association that essentially did a tremendous job of summarizing the scientific basis that was presented to EPA from which they acted at that point in time. And I'd be glad to provide you copies of those scientific publications.
Mrs. CHENOWETH. Would you, please?
Mr. SAXTON. Sure would.
Mrs. CHENOWETH. Thank you.
Page 51 PREV PAGE TOP OF DOC I'm very interested in the fact that Idaho has a Freedom to Farm Act. Our grass burners, for instance, are allowed to burn their fields. Although they cooperate with the local community leaders and the people there and burn them only when weather conditions will allow the least possible discomfort, we're still allowed that in Idaho. Do you intend for these regulations to override the State's authority and their freedom to farm?
Now, my neighboring State in Mr. Nethercutt's district does not have the freedom to farm, but in Idaho, we are a little unique over there. How will you deal with the State laws? Can you invoke a supremacy clause, for instance, when there's been no harm shown?
Mr. JOHNSON. I think you're getting into issues that you ought to have EPA in front of you to deal with. I would answer, though, by saying that we will continue to work EPA to look at good management tools and balance those against issues such as air quality, water quality, and so on. And very often it's not clear-cut.
It's not this is the only way. And, as was mentioned, the Forest Service is very concerned about fuel buildup in many of the forests and the need for prescribed burns. Well, then how does that impact air quality? And we'll continue to be at the table and work through those issues. We think they're very important.
Mrs. CHENOWETH. I see my time is up, but you did anticipate my concern. I join my colleagues Mr. Nethercutt and Mr. Schaffer in expressing our very sincere and serious concern about the conflict between Mr. Babbitt's proposals, the ambient air quality standards that you're trying to achieve.
Thank you very much. Thank you, Mr. Chairman.
Mr. COMBEST. Mr. Schaffer had a request for information as well, I believe.
Mr. SCHAFFER. Thank you, Mr. Chairman.
In response to the question I asked about whether the USDA supports the EPA's 2.5-micron PM2.5 standard that the EPA is proposing, the response was that the Department could not comment.
Page 52 PREV PAGE TOP OF DOC I would just like to ask that the Department be given an opportunity to add to the record the basis to support the claim that they cannot take a position on that whether they have one, and provide justification in the record for not having a position on the matter.
Mr. COMBEST. That request will certainly be made. There may be additional questions that we would need to submit in writing as well.
Mr. MORAN. Mr. Chairman, thank you.
Just a couple of brief questions, I think. What would the appearance be, how would life change on the farm, if these regulations become final? And which regulation impacts that kind of change? Is it the ozone or the particulate matter?
What could my farmers expect to have changed in their lives and their farming operations as a result of the adoption of this kind of regulation?
Mr. JOHNSON. Mr. Saxton, do you want to take the first shot at that?
Mr. SAXTON. Sure. Let's presuppose that we're 5 years down the road I think is maybe what you're asking. Some examples, where wind erosion is a serious problem not only in the sense of losing their topsoil but in terms of emitting dust particulates into the air that's impacting urban areas, other areas, those farmers will probably expect a lot more assistance from the National Resource Conservation Service about controlling wind erosion, new farming techniques, more in the area of conservation farming, residue management.
We anticipate a number of additional best management practices provided to those farmers, help them to adopt them voluntarily as they go. That would be one example.
Let's take an example that's very prominent in the California issue of dust from harvesting machines. Certain times of the year that becomes a fairly significant particulate source because they're using vacuum and sweeping techniques to pick up different nut products.
These machines may well be significantly modified if we ask the machinery industry to participate with us because there are techniques for suppressing those dust emissions right at the machine level.
Page 53 PREV PAGE TOP OF DOC So these would be a couple of examples that I would just put forth that we are looking into as potential changes in the agriculture. We have to recognize that some of these changes may well get involved in some significant economic changes. If they are, then we also need to be prepared, I think, to work with our farmers on the economic side and be sure we're not imposing unreasonable economic liabilities on them as a result of this.
Mr. MORAN. Doctor, you indicated about voluntary compliance participation in conservation programs. Is there not a lever? Is there not leverage? What would someone be forced to do, anything in particular, that you have discussed as being required?
Mr. SAXTON. Well, that's on the policy side. I think I'd throw that back to Paul to answer it.
Mr. JOHNSON. We already have some of that going on with State and local regulations--and certainly you have it in the Northwest--when you can burn or not or whether or not you're going to be allowed to burn even in some cases.
So certainly on the regulatory side, it's----
Mr. MORAN. Let me ask in that example, then. Burning is an issue in Kansas from time to time. But would there be regulations on when a farmer could disc their land? I mean, does it go that far?
Mr. JOHNSON. We'd continue to probably push best management practices. And so I can see the time coming I suppose where farmers would have to implement best management practices, but I would hope that it's always a balance.
You obviously can't harvest your crops until they're ready to harvest or you can't disc any time you want during the year. So what we'd try to do I'm sure is put together best management practices that would help farmers meet some of those compliance requirements.
Mr. MORAN. Mr. Johnson, I don't want to turn this hearing into dealing with CRP, but you said something that caught my attention about the resources required, we need more resources in the Conservation Reserve Program.
Page 54 PREV PAGE TOP OF DOC Is there evidence as to how many acres are highly erodible? Is that a known thing? The 36.4 million acres that we've set aside I assume is set aside in a budgetary way, rather than a scientific or definition way. Do we know how many acres we would categorize as highly erodible in this country?
Mr. JOHNSON. We certainly have those numbers, yes. But I would urge you to look at conservation on the land, including the CRP, as not just an issue dealing with highly erodible lands. That was the definition we used in 1985.
But there are many reasons for using CRP that could be a water quality issue next to a stream. And the new CRP gives us opportunities with what we're calling the National buffer initiative, where landowners can set aside very small strips here and there, whether they be a wind strip to reduce wind erosion or a place for wildlife habitat or things like this.
So we should be looking at this tool as something that you use to satisfy a number of things and not just highly erodible lands.
Mr. MORAN. Let me ask it this way; does the Department have a number in which it would be the optimum number of acres in the CRP Program, for whatever reason, whether or not the highly erodible is the right definition?
Mr. JOHNSON. Well, certainly we support the 36.4 million that Congress last year reauthorized for the program. There's no question about that. The question is exactly how you place them and how you can get the maximum benefits from those.
Mr. MORAN. My time has expired. Mr. Chairman, the Kansas legislature has adopted a concurrent resolution involving the two topics of ozone and particulate matter. And I'd like the consent to have it placed in the record.
Mr. COMBEST. Without objection, so ordered.
[The resolution of the Kansas Legislature follows:]
"The Official Committee record contains additional material here."
Page 55 PREV PAGE TOP OF DOC Mr. COMBEST. Before recognizing Mr. Jenkins, let me ask you, Dr. Saxton, did you say that you had had specific discussions with equipment manufacturers on dust suppression measures?
Mr. SAXTON. Not specific. There are techniques available that could be placed in certain equipment operations that are not now typically a part of that, some of these harvesting machines.
Mr. COMBEST. You may not know the answer to this question, but from your knowledge about it, would it be something that if we contacted equipment manufacturers, they might be able to give us some estimated costs? Are you familiar if they're that far along in their discussions of----
Mr. SAXTON. I'm not familiar with that. I would guess that it's a fairly advanced kind of technology that probably would take some digging on their part. But I'm sure that if they were convinced of the need, they would participate with us.
Mr. COMBEST. Thank you.
Mr. JENKINS. Thank you.
What farm machines, in particular, do you have in mind? Do the folks who proposed these have in mind specific farm machines now? Are we talking about combines? What are we talking about?
Mr. SAXTON. I'm not aware of specific machines as much in my own research area. I think there will be some testimony later on in some of the other scientists today that will be talking about specific operations.
We visually see a fair amount of particulates from several of our tillage operations, from some of our harvesting operations, some of the residue management ones. We are not far enough along in our science to be able to say these are a problem or they're not or they will require remedial measures, but that's a piece of science that does need to be addressed.
Page 56 PREV PAGE TOP OF DOC Mr. JENKINS. But you believe that there are going to be witnesses here who have that information?
Mr. SAXTON. I'm sure that's right.
Mr. JENKINS. All right. I'll ask the question of them, then. Thank you, sir.
Mr. COMBEST. Mr. Smith?
Mr. SMITH of Michigan. Thank you, Mr. Chairman.
And please excuse me if I repeat a question that might have been answered. And if that's the case, then just say that. And we'll skip over to the next question.
Is what some consider an unpleasant smell from livestock manure dangerous to the health?
Mr. JOHNSON. Mr. Smith, I can't answer that question specifically. I can say that we are working with farmers to try to reduce odors wherever possible, but I don't have----
Mr. SMITH of Michigan. So is your answer not to your knowledge?
Mr. JOHNSON. Not to my knowledge. That's a fair answer.
Mr. SMITH of Michigan. I represent a district in Michigan that is downwind from the industrial areas of Chicago and south across the lake. So much of that area is going to likely be a non-attainment area. Does that mean that automatically the regulations will consider that area to come under the additional requirements of the air quality standards for non-attainment areas? Can anybody help me with that?
Mr. MCCLELLAND. Let me help you out generally speaking. I think again this is something that would be good for you to ask of EPA, to ask them specifically about this. What you're asking is if we have new standards, which is the stage of the proposal we're in now of proposing new standards.
In the implementation of those standards, what kind of controls might be required or determined by your air quality management district there in your district as necessary to reach compliance? And I think that the point that you bring up here is another very important point.
Page 57 PREV PAGE TOP OF DOC You're discussing the issue of pollutant transport from one area to another, which points to the issue of how big an area are we talking about when we're talking about controlling all of this because we have serious transport problems in many of these areas?
So it's difficult, sir, to answer your question of specifically what the requirements on your area would be. But I think in EPA's proposals you will find that they have begun to take more of a regional approach with regard to these kinds of issues because they recognize the transport problem.
Mr. SMITH of Michigan. Yes. But what I'm concerned with, of course, is the regional approach says, well, everybody has non-attainment. So let's lay all of these additional requirements down on everybody. Of course, that's a concern.
And it seems to me that suggesting if your non-attainment because of the movement of particulate or anything else coming across your area and, therefore, the new area that's a recipient of that comes under these new high-quality standards is something similar, Mr. Chairman, to saying if you pollute during a high wind and it blows to an area that is already certified free, then it's OK. So it seems to me that something--I mean, that's a great concern to us in my particular congressional district and in other areas that might meet the same kind of endangerment.
Let me finish up with one question on the imposition of rules and Federal law, if you will, sort of a follow-up on States' right-to-farm laws. Would you say that farmers have to go under these new processes, this new implementation of the safeguarding pollution or they don't get something or would you say that we're going to make this a Federal law with a criminal offense?
Mr. JOHNSON. Again, I think we should have EPA in front of us here, but the position we've taken in the past on conservation on private lands is that we believe a good, strong, voluntary approach works. And it should be a proactive approach, by the way, not just let's sit back and wait for somebody to come through the door. Let's get out and work together to----
Page 58 PREV PAGE TOP OF DOC Mr. SMITH of Michigan. Yes. But whether you're looking at the Clean Water Act or the Sodbuster Act, what we've said there is we want you to comply with these Federal guidelines or, else, you're not eligible for the farm program payments or this kind of subsidy or the CRP contract payments, et cetera. And I'm not aware that many of these say, ''Look, we're going to make this a criminal offense and put you in jail if you don't comply.''
Mr. JOHNSON. I know of no move to do that. Again, with the agriculture sector, we have looked at compliance and meeting standards or otherwise not being eligible for certain programs.
But in the case of air quality here and how States want to deal with it, I think that it's something that I don't have the answer for that question other than we will continue to work in a very proactive way and think that we can solve an awful lot of these problems.
Mr. SMITH of Michigan. Right now, Mr. Chairman, EPA is suggesting that because we're non-attainment, not because of our pollution but somebody else's, they want to stick something up our tailpipe and at a charge of something like $42 per test and make this non-attainment area, move it into an attainment area by something that's not caused from that particular area.
So thank you. I appreciate the opportunity.
Mr. COMBEST. As with almost every hearing, we could spend a great deal of time just with each panel. In order to appreciate the time of our second panel, I do have a couple of quick questions that I would like to ask and then certainly give other members the opportunity.
Mr. Johnson, I think you in responding to Congressman John's question were exactly on track. We have been moving in the right direction. We need to take credit for what good has been done.
The concern I have is that that may not be good enough. And we don't seem to have the technology yet to know for certain whether the good we have done is good enough under the proposed new regulations.
Page 59 PREV PAGE TOP OF DOC And so I would ask you or any of the other panel that in the interagency process of discussions with the lack of research available, has USDA urged EPA that this rule will be delayed in implementing?
Mr. JOHNSON. I haven't been working on the interagency panel.
Mr. MCCLELLAND. We have not made that specific recommendation, no, not to my knowledge. I certainly haven't made that. In the technical discussions I have been in, that's not something I have dealt with at all.
Mr. COMBEST. Is it beyond the thought of reason that as this moved forward, that might be something that could be considered? I mean, it's almost as bad to have wrong data as it is to have no data?
Mr. MCCLELLAND. Again, with regard to the PM2.5, there is a court order. And I've read the stuff that's from the court that's been sent to EPA. And the last letter that was sent from the judge basically said, ''This is it. I mean, I'm setting this date. You need to comply here.''
I think that the other issue, though, is that everything doesn't happen all at once here. We do have the standard-setting procedure now. And some decision will be made on what the standards are. And then we will go into an implementation phase if the standards change.
So if you take it for granted that the standards change or you'll make that assumption, then, what occurs is that then we move forward with a number of steps in the implementation process.
With regard to PM, for example, there is the building of the network and there is the determination of what areas are not in compliance with the standard. And then there is the whole series of the implementation steps that each State must go through to provide a State implementation plan that shows how they will attain and then maintain compliance with the air quality standards. So those are a number of steps there.
Page 60 PREV PAGE TOP OF DOC Mr. COMBEST. If there's a new standard implemented, obviously one has to try to do everything they can to live within that standard. I think the question remains that, well, maybe not the question remains, but I think it's extremely important to know the impact of that standard before the standard is implemented so that if, in fact, we recognize that it is just infeasible that recommendations can be made that this is not something that's going to work, before the fact, rather than after the fact, then I think obviously those people on the task force that are representing agriculture, that charge falls to you.
Mr. MCCLELLAND. Let me point to one area that I believe in our technical comments and in the interagency process has been an issue that I think goes right to the question that you're speaking about. And that is in the regulatory impact analysis that was released by EPA.
In the cost and benefits portion of that, there are some areas that, in fact, after--I believe the baseline in that first RIA went out to the year 2007. If I'm mistaken, I'm sorry, but I think that's it. I think what we're looking at now is a scenario that goes out to 2010.
But there are some areas, projected areas, that would not reach attainment by the year 2007. And one of the questions that we have been struggling with in the interagency process--and I think that everyone has been concerned about this--is that if we have areas that don't reach attainment and we basically used everything that's authorized in the Clean Air Act, then what is it going to cost us for those areas to reach attainment? What is the additional cost of reaching attainment beyond that?
This has been a very, very difficult question for us to deal with. I wish I could tell you that I know how we're going to deal with that. We have made a number of suggestions to EPA and to try to, for example, take some of the considerations in the Implementation Advisory Committee with programs like cap and trade, where you basically set a cap on an airshed, should you set a cap on the level of emissions, and then you let all of the players in the air shed trade, as in the Acid Rain Program, for example. I think that that's where cap and trade has been used with reasonable success.
Page 61 PREV PAGE TOP OF DOC We have some of those issues that we have been really struggling with. And I have to tell you right now that I can't say how we're going to deal with all of those, but that has been a serious concern of ours. And we have noted that in the interagency process and have docketed our comments on that particular issue as a specific of what you're talking about there.
Mr. COMBEST. Well, hang in there on that.
Mr. MCCLELLAND. We plan on doing so, sir.
Mr. COMBEST. Let me just make this comment about some of the difficulty. Dr. Coates in a few moments will mention that in 1995 an EPA document suggests replacing all cultivation with herbicides and all crops. And Mr. Isom will tell us that California is already under a mandate by the California Air Resource Board to meet a goal for pesticide reduction by the year 2006. This I think points out some of the difficulties.
Mr. Dooley, do you have further questions?
Mr. DOOLEY. No.
Mr. COMBEST. Any other members of the subcommittee or Mr. Nethercutt have questions they need to followup?
Mr. COOKSEY. Just a comment, Mr. Chairman. I think these gentlemen at this panel are good guys. I hope they're advocates for agriculture and farmers, as all of us on the committee are.
I think it's obvious that the EPA should have been here today. And I think that they should be in a position to explain their rules and their regulations they're trying to put on the farmers in my district. I know the farmers all over the district. And I would hope that maybe Mr. Johnson can come back the day we have the----
Mr. COMBEST. I appreciate your suggestions. The EPA seemed to be dealing more in the area of health and said that they had been before a number of other committees a number of times and agriculture was not something of tremendous significance and importance. But we are going to certainly make suggestions that they appear.
Page 62 PREV PAGE TOP OF DOC Mr. SMITH of Michigan. Mr. Chairman?
Mr. COMBEST. Mr. Smith.
Mr. SMITH of Michigan. I think we still have some latitude on our input and request on the 60-day holding period if we can't get the answers.
Mr. COMBEST. Right. Thank you very much, Mr. Johnson and other members of the panel. We appreciate your being here. I think that Mr. Cooksey makes a very good point. It would be very helpful to have someone here at such point when we do have the Environmental Protection Agency.
Mr. COMBEST. We're going to combine the second and third panels. We'll call it panel 2 1/2. And we would like to invite now Dr. Robert Flocchini, professor of resource science from the University of California at Davis; Dr. Calvin Parnell, professor of agricultural engineering from Texas A&M University; Dr. Wayne Coates, professor from the office of area land studies, University of Arizona; Mr. Emmett Barker, president and CEO for the Equipment Manufacturers Institute; and Mr. Roger Isom, the director of technological services for the California Cotton Ginners and Growers Association. I would invite all of you to appear at the table. And I appreciate very much your being here and the time that you have taken to do this.
Mr. COMBEST. Dr. Flocchini would you please proceed?
STATEMENT OF ROBERT FLOCCHINI, PROFESSOR RESOURCE SCIENCE, UNIVERSITY OF CALIFORNIA, DAVIS.
Mr. FLOCCHINI. Thank you, Mr. Chairman. It's a pleasure to appear before the subcommittee and be able to introduce some information regarding my interests and my research in the particulate matter area.
I just wanted to make a few points. Most of my testimony, of course, is already before you. One of the things I wanted to state is that I've been involved with particulate matter research since 1971.
And I have looked at particulate matter from a number of sources, starting in 1971 with particulate matter from freeways, moving then into urban centers doing research for the California Air Resources Board, looking at particulate matter that impacted the Channel Lake Naval Weapons Center that's transported from the Los Angeles Riverside area into that Mojave Desert.
Page 63 PREV PAGE TOP OF DOC And most recently, I'm involved with the research trying to establish the impacts of agricultural practices on air quality, specifically with respect to the PM10, but also looking at PM2.5 at the same time.
One of the points that I wanted to stress is that particulate matter, whether it's 10, 2.5, 1, is different from other primary pollutants or secondary pollutants that we have examined.
Particulate matter, like other pollutants, can change in concentration on a day-to-day basis, on a site-to-site basis. That's the concentration. That is, the amount that's in the atmosphere.
Particulate matter, unlike other pollutants, also changes in terms of the constituents. What I measured today, here in Washington, DC, as the constituents and also the size of those constituents may not be the same tomorrow.
That is, the make up of PM10, the make up of 2.5 also changes. And I think that's one of the things that we need to really examine. When we talk about particulate matter, it's not a bulk measurement as we have been led to believe.
That is, the gravimetric amount. I think it's also important to understand what the constituents are. And those constituents are variable. And I don't think there's been enough given to that aspect.
A second point I want to make in my introductory comments is with respect to the size of the particulates. This has been addressed earlier today.
But as we move into an area that we start looking at smaller and smaller particulates, we also have to realize that those particulates can stay in the atmosphere for a long time.
And if they stay in the atmosphere for a long time, they can transport. And as you know, I've introduced a paper that some of my colleagues at Davis have published where they have actually looked at Saharan dust and its impact on the continental United States.
Page 64 PREV PAGE TOP OF DOC This is a study that involves more than just the measurement of particulate matter, but also includes an examination of meteorology.
But it's important to realize that when we talk about particulate matter, the smaller the particles, the longer they stay in the atmosphere and the more they can move.
A third point I want to make, and again this is in the introduction to my testimony, and that's about numbers.
As a scientist, I'm very, very sensitive to numbers appearing without any indications of the errors, without indications of the variability of those numbers.
And specifically, I am very sensitive to when numbers appear without any reference so that I can go look at the numbers to see what the conditions that data was collected.
And I think when we talk about poor science, one of the things that we have to look at, the numbers themselves may have been adequately collected and documented, but if we don't look at their applicability in other areas and their ability to be transferred to other areas, we have a significant problem.
So, I just want to stop at those comments and again just to reiterate it, having individuals and agencies realize that particulate matter does change in composition and size. Those particles can be transported a long way.
And that when we look at numbers, we have to be able to identify how accurate those numbers are, what the variability is, and what the source of those numbers are. So, thank you.
[The prepared statement of Mr. Flocchini appears at the conclusion of the hearing.]
Mr. COMBEST. Thank you very much. In order to keep it sort of in the topic area, let's now go to Dr. Parnell.
STATEMENT OF CALVIN PARNELL, PROFESSOR, TEXAS A&M UNIVERSITY.
Mr. PARNELL. Thank you, Mr. Combest. Let me make a point that my testimony today represents my opinion. It does not represent Texas A&M University or the Texas A&M University system.
Page 65 PREV PAGE TOP OF DOC And what that does is free me to answer questions that Mr. Schaffer might be asking me later on about an opinion, because it's my opinion. And I don't have to shade my opinion in any way, shape, or form.
This is not the time I've testified to Congress. And I want you to know that it is intimidating. At one time I was on the Air Control Board, I might add, when Lubbock was having the problem with potential of being designated a non-attainment area.
And part of what came about at that time was the TACB, the Texas Air Control Board, at that time, was assisting your area, Mr. Combest, in not being labelled a non-attainment area when they were working with EPA.
The whole process of regulating air pollution is an excellent process we have in this country. But there is a potential here to become too serious or too vigorous in terms of attempting to get clean air.
In my opinion, EPA is attempting to do that at the present time. I don't say that to be critical of the EPA. I'm saying that the process itself allows that aggressiveness to occur.
One of the things I have observed in testifying to Congress is, in the social occasions prior to coming in this room, people tend to say that they're going to say certain things to the Congressmen.
But yet, when they walk in here, they're intimidated. And they tend to be a little bit more careful about what they say. I'm not one of those folks.
And if you want an answer, I'm going to give you an answer. I might add that I have approximately 10 to 15 former students, including my daughter, that work for the TNRCC, which is the air pollution regulatory agency in the State of Texas.
And they do an excellent job in Texas of regulating air pollution. And I support them. However, it is my opinion that they epidemiological results that were the basis for the new PM2.5 NAAQS and the ozone NAAQS was questionable.
Page 66 PREV PAGE TOP OF DOC And I do not think that they warrant going forward with the PM2.5 NAAQS and ozone NAAQS at this time. Maybe in the future after more data, but not at this time.
It is my opinion that the PM2.5 NAAQS will have significant economic impact on agriculture, a significant economic impact on agriculture if it goes forward. It's frustrating to me as an agricultural engineer to hear that EPA is not concerned about agriculture.
When, in fact, EPA has published a document that says in terms of emissions inventory 34 percent of the PM2.5 is going to come from agriculture and forestry, 34 percent.
And if you add that to construction and roads, approximately 90 percent of the PM2.5 in this country is going to come from agriculture, forestry, construction, and roads, according to the EPA.
Now, when the NAAQS comes in and is implemented, what happens is the States, and I'm going to use the term SAPRA which stands for State Air Pollution Regulatory Agency, because I don't like to use that term over and over again.
The SAPRAs are required to find a way to bring their areas that are in non-attainment into attainment. When they are forced to do that, they basically come forward with a SIP, State Implementation Plan, to show EPA how they're going to get that non-attainment area into attainment.
If a non-attainment area is non-attainment in PM2.5, then where is the focus of the SAPRA going to be? It's going to be in those areas where emissions inventory data that was published by EPA that says 90 percent of PM2.5 comes from agriculture, forestry, construction, and roads.
That's where the focus is going to be. So, how do you get an area that's in non-attainment into attainment? You implement controls. You force people to reduce the amount of pollutants entrained in the air.
In agriculture, how do you do that? Now, I disagree with my colleague who was here earlier. If you go to put in cyclones on the side of a tractor to take the particulate out of the air stream, the PM2.5 is going to go right through that cyclone.
Page 67 PREV PAGE TOP OF DOC It's not going to change. It's not going to be collected. So, you're looking at controls that cost money, but yet must be implemented because it's mandated by EPA that the SAPRAs, in Texas it's the TNRCC, must find a way to get the non-attainment areas into attainment.
So, we're looking at controls being placed on agriculture. Irrespective of what is said, we're looking at controls being placed on agriculture. Now, we go back and look at agriculture.
And Mr. Johnson pointed this out earlier. We look at other industries, they can pass the cost of these controls onto their consumers. Electricity, you can change the price of electricity.
Can you imagine a farmer coming along and saying, ''I've got some corn out there. I've got to have $5 a bushel. I'm not going to sell it to you for $3 because I'm going to lose money.'' No way.
You can't do that. If the market price is $3, they have to market it at $3. Let me make one other point because my time is getting ready to run out. Two other points.
The statement made by EPA that the ozone standard, the new ozone NAAQS standard, is going to save production in agriculture a billion dollars per year is not true. That's my opinion. That is not true.
Some environmentalists say it's $1 to $3 billion per year, and at the same time, they'll come to an EPA briefing on the new ozone NAAQS and say, ''You know, the new ozone standard is not low enough because it's almost the same or nearly the same as what we used to have.''
Now, the question is, and let us not complicate it, Mr. Combest. If you have something new that's almost the same as what something old was, then how can you save a billion dollars a year?
I mean, that's a simple comparison. It's not necessarily an engineering concern. Let me make one last statement because my time is up.
Page 68 PREV PAGE TOP OF DOC We have some real problems with some emission factors that are published by EPA that were grossly in error. Now, I was careful not to couch that in simple terms, in non-confrontational terms.
They were grossly in error. We're working at Texas A&M at trying to improve some of those numbers. But those numbers were used to develop these numbers where they say that 90 percent of the PM2.5 comes from agriculture.
And that's part of the reason why we have those difficulties. We need to have agricultural engineers involved in the rule-making process.
And we do not have that in the EPA and in many of the contractors for EPA that are coming up with the studies that are generating these emission factors.
At the TNRCC on the other hand, we have in the neighborhood of 15 agricultural engineers doing the regulation of air pollution in the State of Texas. It's one of the reasons why I think we have the very best regulatory agency in the United States in Texas.
We need more agricultural engineers in EPA and in the agencies that did the studies for EPA. Thank you very much.
[The prepared statement of Mr. Parnell appears at the conclusion of the hearing.]
Mr. COMBEST. Thank you, Dr. Parnell.
STATEMENT OF WAYNE COATES, UNIVERSITY OF ARIZONA.
Mr. COATES. Thank you for the opportunity to provide some input this morning. A little bit of background so you know where I'm coming from.
I have farmed, grew up on a farm. I've been involved with agricultural machinery design and testing professionally for 25 years, working in the particulate area for 10 years now.
Page 69 PREV PAGE TOP OF DOC And the reason I got involved is because the Arizona Department of Environmental Quality contacted me because there are problems with air quality in Arizona, saying, ''How can you help us by getting us some data?''
I believe, as Dr. Parnell said, that if the 2.5 is implemented, it is going to significantly impact agriculture. There are going to be restrictions placed on our field operations.
That's the main thing I want to address here today. And this could include limiting the number of passes, limiting such things as what moisture contents you could operate, limiting what days, humidities, wind velocities, all kinds of things like this.
In addition, it could require installing equipment on the machines to reduce the particulates. What types of things, who know. But no matter what you put on, it's going to cost money to put them on.
And it's going to cost money to operate. And it's impossible really at this time to say these costs, but it is going to be significant.
To give you an idea of what might be enacted, consider the South Coast Air Quality Management District in California. They recently, in February, enacted some restrictions on agriculture
They themselves--this is the Los Angeles, Orange County, Riverside, San Bernadino counties. They themselves say only 5 percent of their particulates come from agriculture.
But still they're restricting. And an interesting one is, for example, hay grinding at livestock operations must cease between 2 and 5 p.m. if visible emissions extend more than 50 feet from the site of the grinding.
Not 50 feet off the property, but 50 feet within the property line. So, that's an example of something that could come down pinning people that really it's incorrect.
I want to talk a little bit about what's called the emission factor equations. When we talk about agricultural tilling operations, the present equation that is used by EPA and then is mandated for all the States to use was developed from only 18 tests at three sites using four implements.
Page 70 PREV PAGE TOP OF DOC Not very representative. The equation as it sits now, the only variable in it if you want to calculate the amount of emissions an implement puts out is the silt content of the soil.
It doesn't say anything about moisture content, speed. I've heard a number of you are farmers. You know that speed, moisture content are going to affect the amount of emissions.
But the State agencies, as Dr. Parnell said, must use this equation to estimate. When an emission, or an exceedance is recorded, what happens is we go around these agencies to decide where this is coming from.
And it's not particularly measured where it's coming from. You estimate where it's coming from. And I want to talk about Arizona, the southwest corner, Yuma County.
They did one of these emissions inventories. And they determined that 40 percent, non-attainment, 40 percent is from agriculture. Forty percent is from unpaved roads, and the 20 comes from other sources.
They didn't take into account a natural large sand dune area west of Yuma which you've seen in movies. They do a lot there. That was never considered.
And earlier we heard testimony that natural events can be considered. But you have to prove that the natural event was the cause.
It's not a de facto situation. In this inventory they did in the Yuma area, they assumed all non-orchard land was tilled 12 times a year. That includes alfalfa fields.
They used a default silt content in this equation of 8 percent based on one test for the whole area and not using the correct procedures. In July 1995, EPA issued a new draft AP42 standard.
Here we thought there was some hope on the thing that there was going to be a new change in this equation that's used for estimating emissions from agriculture tilling operations.
They have concluded at this point, the last I have seen, to update the narrative portion only. They said the equation is fine, that there's nothing. Some of the recommendations, and one of these was cited earlier, was that herbicides should be used on all crops.
Page 71 PREV PAGE TOP OF DOC That we should use punch planters for cotton. That will be a 50 percent reduction in tillage. We should aerial seed alfalfa and wheat which will give a 50 percent reduction in dust emissions.
We should use laser directed land planes. And they claim in there that this is a novel implement. I think this shows their basic, EPA's lack of knowledge of agricultural practices.
Yet, we have to live within these guidelines or rules. The national air pollution emission trends, they estimate the total from the States and the emissions from agriculture tilling.
What they have done is they have taken the silt content by county, calculated the number of acres, and calculated our total emissions. This is not the procedure that is to be used.
In other words, any clay in your soil, if you estimate what your silt content is, by EPA's definition clay becomes total silt. So, you can have fields that are 80 percent, for example, silt content. Obviously emissions are very high.
We are dealing with a situation with many problems. EPA fails to address these when presented with technical criticisms of their work.
They have a tendency not to respond which is very frustrating for all of us in the area trying to bring forth some credibility to the whole thing. Agriculture has a role to play. But let's determine what that role is. Thank you.
[The prepared statement of Mr. Coates appears at the conclusion of the hearing.]
Mr. COMBEST. Thank you very much.
STATEMENT OF EMMETT BARKER, PRESIDENT, EQUIPMENT MANUFACTURERS INSTITUTE.
Mr. BARKER. Thank you, Mr. Chairman. I accepted the invitation to participate on the basis that you were going to have a group of distinguished scientists and government people on the panel.
Page 72 PREV PAGE TOP OF DOC And I felt perhaps I could bring a little insight as to what really happens down, shall we say, in the trenches on these situations when they evolve.
I must confess that when I was contemplating that, I really had no idea what a mess we've got here. And what I believe significant, some of the things that I want to call your attention to will be in your contemplation of this issue.
In my written comments, I made a number of points. But I'm going to--you suggested earlier in keeping with your recommendation, you want it plain and simple. I'm going to give it to you plain and simple on this.
First of all, we should not lose sight of the fact that regulators are in business to regulate. Everything else is secondary.
When questions of fact are at issue, regulators are quite adept and skilled at positioning the environmental issue relative to the data to receive the benefit of the doubt from the public and the courts.
Regulators have no hesitancy in using data of marginal efficacy. If it provides sustenance to their regulatory intent, it enhances public support on the issue. Trust me, we would never go that far.
And we need your input to make good decisions or the bomb that is easily and generously applied by the regulators before the final rule appears.
And I make these points not to demean the regulators, but to be sure that this committee who created the act to start with, not your particular, but Congress, and EPA is just enforcing the Act within the framework that was given to them to do it.
And so, if there is some basic problems in how EPA is going about doing this, I would suggest that it behooves Congress to step and look at this process and look at the enabling legislation that created the situation in which EPA is operating.
One point that was brought up a little bit earlier, and I believe it was by the lady about some of these issues and you referred to it a little bit, we can have input and we can talk about these things, particularly when Chief Johnson was talking about the need for voluntaryism and being able to use flexibility at the local level.
Page 73 PREV PAGE TOP OF DOC Gentlemen, that's no longer an issue. That's not a option. That was done on the day, the 22d of March I believe, when the hearing closed, unless you and Congress are prepared to take some action.
The reason I say that is that within 1 year, if this new standard goes through and EPA promulgates it, the States have to come up, and the Dr. mentioned this a moment ago, with a State implementation plan.
And this has been one of the issues the Governors have raised because they said, ''We haven't the foggiest idea in the world what we should put in this.'' EPA says, ''Sorry, but the law requires that you do that.''
So, they have to come up with something. Our experience has been that once these proposed remedies, no matter how outlandish they may be, get into more or less the public thinking, you will never erase them back from the collective thought and the process that will show up in lawsuits.
They will show up in testimony from time to time over a long period of time. And then, third, that while farm machines using certified controlled emissions, engines, are going to cost more than otherwise would be the situation, the cost has been understated by EPA.
And they acknowledge that. It may well be that the cost of complying with the ancillary regulations that we were just talking about a bit earlier in the south coast air basin and these other areas is going to be more significant, even the cost of the engines.
And the purpose for making these points is to illustrate the magnitude of the changes that are going to be imposed upon agriculture.
With all due respect, having been one raised on a farm, I spent my life in agriculture, we have had in agriculture a bit of a natural exemption, if you will, in many, many areas.
And I submit to you that that will not be true in the case if these proposed regulations go into place. And the reason for that is no Governor is going to give up his State funds in order to protect a farmer's situation or an agricultural situation.
Page 74 PREV PAGE TOP OF DOC And whatever it's going to require to be implemented is what they are going to put into their plan.
So, I have these recommendations. First, there must be a clear understanding of just what the problems are to be resolved. And some of our panelists have talked about that earlier.
And we believe these are the areas where ARS, and particularly our land grant college, university researchers, ought to be brought in and ought to be funded. And I was pleased that the appropriations people were here and made a commitment in that area.
Then we believe that once such determinates are made that our industry, the equipment industry and others, will invest research dollars of their own and dollars in manufacturing to bring out the products if needed that will help address these issues.
We've done it in the past with no-till, for example, and we expect to do it again just like we're doing today in precision farming. I happen to be chairman of the AG Electronics Association.
And that's one of the big issues that we're involved with. Within the framework of developing rational approaches to research, I strongly believe, not just because I'm a member of it, but I believe this task force on agricultural air quality can be a significant contributor to bringing about rational approaches to these issues.
And I hope it will be relied upon not only USDA, but by EPA as well. And that was one of our recommendations. Thank you, Mr. Chairman.
[The prepared statement of Mr. Barker appears at the conclusion of the hearing.]
Mr. COMBEST. Thank you very much, Mr. Barker.
STATEMENT OF ROGER A. ISOM, DIRECTOR OF TECHNICAL SERVICES, CALIFORNIA COTTON GINNERS AND GROWERS ASSOCIATIONS.
Page 75 PREV PAGE TOP OF DOC Mr. ISOM. Thank you and good morning. For the sake of time here, most of my comments have already been submitted to the record. So, I'll get down to the highlights and tell the main reason that I'm here today.
In California, we've already been through this process. And if there's one thing that we've learned going through the PM10 process is, is that you can't jump ahead too fast.
EPA, when they set their PM10 standard back in 1987, they not only set the standard, but they also put in attainment deadlines long before we knew who the PM sources were and how we could control those sources to get into attainment.
And we are now sitting in 1997. We are still not in attainment. We are serious non-attainment in several of the areas in California. And there is no good prognosis that we're ever going to be able to achieve that attainment.
And we're still learning some of those sources. As a matter of fact, one of the points was made earlier that it's insignificant for agriculture. Well, that sounds strange coming from EPA because they've been pointing their finger at us for 10 years now.
And one of those reasons is the inventory that they have, as Dr. Coates alluded to earlier, for agricultural operations, they have things like discing alfalfa several times a year, rice 13 times a year in northern California.
And they even have dry range land in the mountains being disced twice a year. So, all of that acreage times those emissions has pointed to agriculture as being one of the largest contributors.
As noted in my comments, we've worked to try to reduce or address those deficiencies in the inventory. And some examples, you know we've reduced the tillage emissions by 30 percent just by getting the right number of passes and the right acreage into that inventory.
We've reduced wind erosion by 80 percent just by counting that in California we irrigate our crops. They assumed that we dry land farmed all the crops in California.
Page 76 PREV PAGE TOP OF DOC Another one was the engines that we used to drive the pumps as you were talking about earlier, they assumed, based on some assumptions, that the emissions from those engines were greater than all of the cars and trucks in the San Joaquin Valley.
When they went out there and actually interviewed the farmers as to exactly how often do you use it and what fuels do you use, went to the equipment manufacturers and got the actual emissions information for those particular engines, they found out that that source was insignificant.
And yet, the air districts, and now we're ready to move forward based on that first cut inventory.
Because of that inventory deficiency, we've looked at things, and again this was mentioned earlier, we've had to address water sprays on the back of discs. We have things like no spray days, no-till days.
And this isn't just something I made up. South Coast rule 403.1 says that if the wind is predicted to exceed or exceeds 25 miles an hour, you cease all farming activity.
That is in regulation now. We've also had to look at punch planters as was mentioned earlier. And as the picture you have in your packet there, we've even had to look at diapers on cows.
I mean, that's the extreme that it's gone to. So, to say that agriculture is insignificant really baffles me.
As to the cost impact, it's hard to speculate when we don't know who the sources of PM2.5 are or how we can control those. But just based on some of these things, I can tell you that one of the areas that we see impacted by PM2.5 is diesel.
In California, we have a California-only diesel fuel. We pay higher diesel costs than anywhere in the Nation just because of that because nobody else uses our fuel, and the refineries have to gear up and pay to produce that fuel only for sale in California.
Page 77 PREV PAGE TOP OF DOC Pesticides. They've already addressed pesticides in the PM10 SIP, their State Implementation Plan, in California. We have to reduce pesticide emissions by 20 percent.
And yet, if you ask them, they cannot tell you how much pesticide emissions contribute to the PM10 concentrations. Cotton gins. We're going to have to look, it's already been talked about, look at what they call lo-NOx burners or burners that have low emissions.
Those costs right now are approximately twice the cost of the conventional burner. So, we're going to have some cost impact there.
But where it all boils down to is that further study needs to be done. We need to support USDA and some of the funding of programs that we've done.
We have a regional study, particularly our study that we're doing in California, that is already giving us great benefits. One of the things that has come out is that EPA and all of their PM10 guidance documents, all of it is related to fugitive dust and wind-blown dust.
And yet, if you look at the San Joaquin Valley air quality data and the meteorological data, we don't have a wind-blown dust problem. When the wind is blowing, the PM10 concentrations are low.
So, what that means is that we would have been mandated to meet all of these EPA requirements, and we still would have been in non-attainment.
So, what needs to be done is this research needs to be carried out. We need to do these studies and determine who the sources are and how they can control.
I don't think agriculture is trying to run and hide from these things. We're just saying that if you're going to impose regulations on us or requirements that they truly be based on sound science and show that there is going to be some environmental benefit.
And we ask that those types of decisions or judgments be made before you set a new standard and attainment deadlines to go on. Thank you.
[The prepared statement of Mr. Isom appears at the conclusion of the hearing.]
Page 78 PREV PAGE TOP OF DOC Mr. COMBEST. Thank you, Mr. Isom. Growing up on a farm and ranch, I can tell you I do not want the job of changing the diapers on those cows.
And, Mr. Barker, you made a good point that Congress was, or the authority originally arose, I want to make for sure the record shows that we voted on that issue in 1990.
I was one of 21 in the House that opposed that. And that's what we're looking at now is what do we need to do to change that authorization so that it passes the logic test.
This would be a question I suppose for the technical. And I've certainly got some questions for those of you who are not as technical. Let's take an example.
My home town of Lubbock, TX was declared non-attainment because of dust particles in 1990. Is it technically possible to determine in measuring the dust in a community?
Nick Smith had some of these same problems they've got that come downstream or downwind, to determine the origin of those dust particles, that they didn't come from 2 miles away, that they came from a hundred miles away?
Mr. PARNELL. Do you want to talk, Bob?
Mr. FLOCCHINI. I can give that a try, Mr. Combest. I think that if you take the measurements as they are now being taken, that is, a gravimetric measurement.
That is what they do. They pre-weigh a filter, and they post-weigh a filter. And the difference being the total amount of mass that's on that filter.
From that measurement, you cannot determine the sources at all. It just gives you total mass, the weight of the material that's accumulated on the filter.
Now, some of the research techniques that we've developed, and other people on this table have developed over the years, you can actually take filter samples. You can do speciation.
That is, you can determine the components or the constituents that are on that filter. That gives you information. It gives you more information.
You then have to combine it with statistical techniques and knowledge of sources to determine potential sources. That just gets you the first step.
Page 79 PREV PAGE TOP OF DOC The paper that I introduced with the Saharan dust, if people have a chance to peruse that, they'll see that you also then have to know something about the wind patterns. And you do what we call trajectory analysis.
So, to take a simple filter with mass and to infer that it has--well, it does have the information about sources, but that you can infer what the sources are is not correct.
You have to have a lot of additional information to do that. And I think that's the best way I can answer the question.
Mr. PARNELL. Let me comment, Mr. Combest. Actually, Lubbock was not designated non-attainment in 1990. What was happening was there were three exceedances, and EPA was dictating to the Texas Air Control Board at that time that Lubbock should be designated non-attainment.
The Air Control Board basically went back to EPA and said, ''Look, EPA, this area had a dust storm every time we had an exceedance.'' Concentrations exceeded 150 micrograms per cubic meter. That was an unusual circumstance.
At that point in time, I happened to know something about what was going on there. The people at Research Triangle Park said, ''We don't understand dust storms, and if you have three exceedances, it should be designated non-attainment.''
So what happened was we had some representatives of EPA come to Lubbock along with the Texas Air Control Board. I think you might have been there as well.
It just so happens on the day in March that they showed up in Lubbock, TX, there was an excellent dust storm that took place. All of a sudden the EPA people got educated. We got it unclassified instead of non-attainment.
Mr. COMBEST. The point is that the recommendation for non-attainment was able to be dealt with because of conditions which were able to be pointed out.
That is a concern in talking with USDA earlier that I and others have. And that is, if you can look at situations as they occur and be able to have, as I would say in Lubbock, wriggle room, that gives you a chance to deal with unusual circumstances.
Page 80 PREV PAGE TOP OF DOC If it's a blanket overall policy, that No. 1, is even difficult to determine the origin of the problem. It is virtually impossible to comply with.
Mr. PARNELL. One of the difficulties of this whole issue is that if you were to talk to EPA folks and they were here, they would say that there was limited funding and limited resources.
They were covering toxics and all these other issues, and that agriculture is not a high priority as some of these other HAPS and this kind of thing. As a consequence of that, I think some of the other panelists can attest to this.
They tend to not be very open for that wriggle room that you're talking about there. One of the difficulties if you go forward with the PM2.5 NAAQS is how open are they going to be down the road?
If they're not open down the road on PM2.5 NAAQS, we're in some deep trouble in agriculture.
Mr. COMBEST. That obviously is a major concern. You're talking about the amount that comes from agriculture, from travel on dirt roads and other kind of agricultural practices.
I've noticed that dust has a tendency to blow if you're driving down a dirt road. Mr. Isom, in your testimony, one of the interesting ideas was suggesting that trucks be shaken before they leave a field.
I'm going to be real interested to see what kind of equipment that's going to take to shake them and who exactly is it that's going to buy them and not counting the wear and tear on the truck itself.
But have you looked beyond to see kind of what the anticipated cost might be for some of the measures that you have looked at in terms of either ginning or other agricultural practices in cost?
Mr. ISOM. Only one specifically because it actually did come out as a requirement has been the burners on the gin. And we're talking spending close to $60,000 to $80,000 per gin in additional cost beyond a burner.
Page 81 PREV PAGE TOP OF DOC It would be double that if you had to replace, actually take out your old burner and put the new one in, but well over $100,000 to retrofit a gin.
Most of the other ones to this point, we've been able to point out to the Air District and to the State Air Resources Board that a question like the one you're talking about the truck, shaking the trucks so that you don't carry out mud or dirt onto the road, we've been able to point out to them that what's the impact?
How much PM10 are you going to reduce by us cleaning the wheels or shaking the truck. And they honestly can't answer that question. So, we've been able, at this point, successful in keeping that off.
But the other cost we've looked at is there was a chance where they wanted to permit farms. And each individual farm would have its own air pollution permit as would an oil refinery or cotton gin.
And you would have to pay the fee, and you would be inspected annually as a regular stationary source would be. And that would be upwards in $300 in permit fees that you would have to comply with.
As far as the other ones, I couldn't answer that question.
Mr. COMBEST. Mr. Dooley.
Mr. BARKER. A point on this cost thing. I asked the other day because I believe one of the requirements in the South Coast Program is that if you drive your tractor up onto a paved road out of the field, tractor or combine, and as we know it is oft to leave dirt on the road for a period of time, you have to go back in there and clean that off.
And in order to do that, I did a little checking. And you can buy a PTO driven 3-point hitch sweeper for your tractor for about $3,500.
Now the problem is the requirement also calls that it has to be a vacuum from which there is no additional release. Those run about $25,000 to about $35,000. So, while we say well this won't be, it's in the law, and it's there.
Page 82 PREV PAGE TOP OF DOC And it could be applied to you. And earlier we talked about penalties that could be--I believe you, sir, you made or someone else was talking about the penalties that could be put on farmers.
Once these regulations are in place, you can be fined just like any other source and become criminal as well.
Mr. DOOLEY. Thank you. I would like to focus a little bit on the issue of the science that was utilized for the promulgation of the new EPA proposals. And I guess my interest is is that some of you have basically challenged some of the findings.
Mr. Flocchini, I was interested in your assessment of some of the EPA analysis. I don't know how familiar you were with it, but you said you were concerned.
You see numbers, but sometimes you don't have access to the data in which those numbers were generated. One of the ways in which the EPA has been trying to generate support for their new proposals was that they would with the PM2.5 standards that we would prevent 40,000 premature deaths based on that.
Now, is that a number that you think can be verified?
Mr. FLOCCHINI. Mr. Dooley, with respect to the health effects, it's beyond my area. I'm not a medical doctor.
In terms of numbers in general that the EPA has used, I think Dr. Coates and Dr. Parnell have identified, and referred to AP42, the EPA guidelines for assessing particulate emissions from agricultural practices.
My comments were more with respect to those. I think those numbers are very, very limited in their scope. They were taken for a specific situation.
And then to apply them to almost all farming practices is totally incorrect. I think that the only variable--there's one variable mentioned. The problem that occurs is that there are more variables when you look at emissions from farming practices.
Page 83 PREV PAGE TOP OF DOC Our own data which I included some in my testimony shows that there's a tremendous difference from almond harvesting, for example, and cotton. Or from even almonds and figs.
And those are the kinds of things that are not allowed in the AP42 determination. So, the point that I would make when I talk about numbers is that you need to know where they can be applied.
And you need to know what transferability they have. And that's where my own area of expertise lies in the research that I'm doing. It's interesting.
I also want to return to Mr. Combest's question because you mentioned can we determine sources? Samples are collected at a specific site and then, even if we were to do that analysis at that site, we would find geological material.
I could not at this point tell you the difference between wind-blown dust, emissions from almonds, emissions from figs, anything else that includes geological material.
It's impossible at this time to determine. So, is it wind-blown dust from public lands? Is it soil erosion? Is it harvesting? We can't make that determination from a filter even if you use the techniques that I had, that I utilize in a research mode.
So, those are the numbers that I think that we need to have more information because they are being applied, as was stated earlier, to incorrect acreages, multiplied by the numbers of times people till.
And so, you propagate the area. You start with an error. You multiply it. It propagates. And at the end, you have something that you have no confidence in at all. And maybe a factor of 10, 20, my colleagues can comment how far off they could be.
Mr. DOOLEY. That's overall one of the concerns is that we see, and many of you testified on the emission inventory data and how this is inaccurate, the formula to identify is inaccurate, whether it's based on a silt index or particulate size of the soil, which the EPA has used to identify in broad terms where the emissions as it relates to PM10 are going to originate or PM2.5.
Page 84 PREV PAGE TOP OF DOC I guess is there any ideas from the scientific community that has done research on this on what is a better alternative in terms of developing the formula?
Obviously Mr. Combest and I would, I think our cause would be certainly substantiated and supported if we could come up with something that is going to be far more effective in identifying what the potential emissions might be or sources.
Mr. COATES. Well, I think the basic problem with what that one equation we have now is, as I pointed out, is it's so limited. It was done in such a restricted situation or number of situations.
What has to be done is there has to be a significant amount of information, more tests run to develop an equation. It's probably more likely a set of equations to predict what happens in this type of situation versus that situation in different parts of the country with soil moisture contents and everything else, different implements, and this sort of thing.
So, really what we need is a series of equations that more closely approximate what would take place and take into account such things as soil moisture content. Because clearly, without soil moisture content, where are you?
It's wrong. It's dead wrong. And this isn't taken into account, speed of the implement. Just very basic things even would help. Type of operation, depth of operation, what had happened on the field before.
You know, if you go into work a field that hasn't been worked for a year with a disc or you go into a field that was previously disced, and the next operation is discing, it's going to effect what happens with that situation.
Mr. DOOLEY. Mr. Isom, I know that you've been involved with a group, an advisory group, related to air pollution that has been helping to put together a regional study in California as it relates to PM actually going down to 2.5 is current underway.
I think the committee would benefit if you could talk just a little bit about where we're at in that process and when we think we might have some further information related to some of the issues we've talked about.
Page 85 PREV PAGE TOP OF DOC Mr. ISOM. That's a huge study that's going on. And it's covering all the bases. I mean, it's going from measuring emissions from cotton harvesters and stock shredders to measuring ammonia emissions from native birds to trying to determine where the dust comes from.
If you have a sample, as Dr. Flocchini said, and it's 70 percent geological material, where did it come from? Did it come from unpaved shoulder of a paved road or a farming operation?
And if so, which operation? They're also developing a model that will be able to take all the emissions from all the sources and model how those emissions get into the urban areas and what impact these rural farming operations have on urban areas.
It's also addressing fire places, cars and trucks and how they contribute to PM10. One of the biggest areas it's trying to address is not just this primary geological material, but also what you find when you get in these smaller particles, PM10 and PM2.5, is the secondary, these combustion contaminates that form the secondary portion.
In the winter time in Fresno, the study has already found out that 85 percent of the PM10 is PM2.5 and it came from combustion, high carbon. And so, the study is just in its beginning stages right now.
But it's attempting to address a lot of concerns. Not just the emissions inventory, but some of the other things. And maybe Dr. Flocchini can expand on that portion of it.
But as far as the farming part of it, we're measuring emissions from fertilizer applications. We're measuring emissions from almonds, cotton, walnuts, figs, from all of the harvesting type activities.
We're also measuring emissions from land preparation activities. And then, of those sources that we do find to be significant, we're moving them into the next phase which would be to try to attempt to find out what kind of controls can you put on there.
And if so, which ones are the most effective and least costly to implement and/or different types of ways of tilling--emissions. And that's the next phase that we'll be getting into. For specifics on the other portion of it, I would turn that over to Dr. Flocchini.
Page 86 PREV PAGE TOP OF DOC Mr. FLOCCHINI. I'd like to first of all comment that it's absolutely critical that individuals like Roger serve on that technical advisory committee.
I was part of the initial discussions that the California people had with respect to that program. They were going to do a summer study, and they were going to measure certain parameters.
There was no thought given to were there any agricultural practices even occurring at that period. And even more so, one of the figures that I included in my testimony, the peak in California emissions occur in October, November, and December.
And they were proposing a California study in the summer. So, I think it's important to have individuals that understand agriculture participating in this.
Because California would have spent millions and millions of dollars doing a study that really did not even address their periods where they violated. In fact, in the summer they do not violate the Federal standards.
In terms of some of the other areas being addressed, they will be looking at not only agriculture as we've said, but they will be looking at the transportation sources. They will be looking at the stationary sources.
And those are all critical because it's the combination that we have to understand. And it's especially critical when we look in the San Joaquin Valley where the peak emissions are occurring in the winter that we especially address what Roger has mentioned.
I include as figure six in my testimony the results of that California study that show during the winter, most of the particulate matter is 2.5 micron, and I made the comment that it's carbonaceous in nature.
Again, I got involved because some individuals came to me and said, ''EPA is saying that agriculture is the primary group that violates the standard.'' It was easy to see that a lot of the agricultural activities were in the summer.
Page 87 PREV PAGE TOP OF DOC The standard wasn't even violated. That's pretty straightforward. Now, we then move to the winter, and we start looking at things. And data that we're seeing, it's carbonaceous type material.
It's material that comes from your fire places, from other potential sources. So, we have to sit and we have to do these kind of studies so we can look at all the individual sources.
California is attempting to do that. But I think it's only possible if we have an integrated approach and include all the people that are stakeholders in this.
Mr. DOOLEY. Well, I thank you both for elaborating about that. And just for the committee's information is that this is a study that received some Federal support through USDA, Department of Defense, Department of Interior, and EPA contributing, as well as State and local and private sector funds.
And we're hoping to see this study concluded in about--what's the time line we're looking at? Is it 5 years or so? It's about 5 years.
Until we get this study completed, it's difficult because this would be the most comprehensive study dealing with PM10s and even some of the other pollutants.
And until we get some other information that's going to be provided on this, it's difficult for us to support any EPA, additional EPA, proposals.
Mr. COMBEST. Thank you very much, Mr. Dooley and gentlemen. Mr. Schaffer.
Mr. SCHAFFER. Thank you, Mr. Chairman. I'd like to ask Dr. Flocchini. You mentioned that these particles can change in size once they're airborne.
Just as far as a trend, which direction do they change? Do they become larger or smaller as they are floating around up there?
Mr. FLOCCHINI. I actually didn't say that they change in size in what I've stated so far. I said that particles when they get in the atmosphere, depending on their size, can remain there longer.
Page 88 PREV PAGE TOP OF DOC The bigger particles because of gravity will fall out. And if you have very, very small particles, air resistance tends to keep them up in the atmosphere longer. And they'll stay.
Now, in terms of the question you just asked though, what happens with certain particles as they get into the atmosphere? And this is more with particles that degrade visibility. They're particles that can attract water.
So, a particle can be emitted into the atmosphere, and it serves as a nucleus for water. So, the effective size of the particle goes up.
And when you look at visibility degradation processes, that size, what we call the scattering area, determines how much a particle can affect visibility. I'll give you a specific example.
Sulphur is very, very hydroscopic. That means it picks up water. And as it picks up water, it has the ability to scatter light. And so, it is very, very effective as a visibility degrading agent.
Mr. SCHAFFER. Let me just ask about the history. This is pretty fascinating. But before human beings existed, what was the condition of the atmosphere with respect to PM10, PM2.5 at that point in time?
Volcanoes, wind storms, I guess there's probably particles that even come from ocean breezes off of waves, salt crystals. I don't know what else is in there, but what was life like before we ever got here? What was the air like?
Mr. FLOCCHINI. I don't know about life, but let's look at air. One of the courses I teach is introductory air pollution course for non majors.
And in that course, we look at natural sources versus anthropogenic sources. And a couple examples I use are volcanic eruptions. And I think probably everybody here would be familiar with Mt. St. Helen's.
And it was very nice because at that point we had satellite images, and we could see exactly once the volcano erupted the plume of that eruption move to the east, then it moved to the south.
Page 89 PREV PAGE TOP OF DOC And people were able to track it. There was a volcanic eruption in either 1815 or 1816, Mt. Tambura which was in the Dutch East Indies. And this is one of those eruptions that 5,000 feet of the mountain went up into the atmosphere.
And if you look at history, the year following that eruption was one of the most severe winters in the northeast part of this country. And a lot of people migrated west because of that severe winter.
So, we're still in a period where we have people, but we didn't have industry in 1815, 1816 like we do now. So, I think that you have to look at natural sources versus anthropogenic sources.
And if you actually look at total emissions on a global scale, I believe the only pollutant that humans emit more than nature is sulphur dioxide. All the other pollutants on a global scale are emitted more by nature than by humans.
So, that's a partial answer to your question. The pollutants are there. For us, as policy-makers, it's important to understand these concepts.
When I walk right on the other side of that door somebody has a bouquet of flowers out there. You can smell it. What am I inhaling when I smell that with respect to particle emissions?
Does anybody have more biology background than I have? I don't know the appropriate term, but there are things emitted just as you would have pollens in the air and other materials that come----
Mr. SCHAFFER. Pollens or spores, can they be PM2.5? Can they be that small? Those are microns that we're talking about, right?
Mr. FLOCCHINI. Yes, we're talking about microns, 10.6 meters.
Mr. SCHAFFER. So, I'm told that some mushroom spores, for example, are that small actually?
Page 90 PREV PAGE TOP OF DOC Mr. FLOCCHINI. Let's accept that that's true, for example. And I think that if we accepted that premise just as we would what comes out from flowers. It's something that comes from the flowers that interacts in your nose.
And it causes a sensation. If they are of the right size, they could be collected on a filter substrate. We don't analyze, at least in our research at Davis.
We're looking at more of the physical parameters right now, the elemental concentration and some of the chemicals. The next step, of course, is to really look at the pollens, to look at the particles that cause odors.
We haven't moved forward into that area yet. We're still at the basic step one, trying to figure out what's going on.
Mr. SCHAFFER. Let me squeeze one more question in here for Mr. Coates. In your testimony, you said that adopting the new PM2.5 standard would significantly affect agriculture, and that agriculture will be increasingly blamed for source of particulates.
And you go through and make some statements and estimates as to cost to agriculture. The Department of Agriculture sitting here just before you, as you heard, has been looking at this in an advisory capacity.
And being an advocate for agriculture in this whole discussion within the Clinton administration for the last 3 years, after their 3 years of study, they've yet to come to the same conclusions you have.
I would like you to comment either as to the confidence we should place in the Department of Agriculture's advocacy for agriculture in this particular discussion versus virtually everybody here who's testified and come to a very solid conclusion about the impact of 2.5 microns.
And yet, these individuals who work for the same Federal Government or Administration that is seeking to impose these standards hasn't come to that conclusion yet. Can you just comment on that dilemma and what that means for the American farmer?
Page 91 PREV PAGE TOP OF DOC Mr. COATES. I'll try. Again, going back to this crazy equation that is wrong. If we go to 2.5, first of all, they're going to use the same equation.
It's wrong for PM10. All you do is change the multiplier and it's going to be used for 2.5. So, the equation is so bad right now. This moving target of how much agriculture is putting out, a while back EPA was arguing, ''No, agriculture isn't going to be effective.''
This was a few months ago. Now, the latest thing they're talking 34 percent is going to be the fine stuff. Our studies we've done--I did a series of studies where we measured from various tillage systems and various operations.
Our data has shown that as much as--and we're talking total solid particulates here, even larger than the 10. The equation over predicts 20 times on this data.
So, we've done enough studies that I feel confident that agriculture is being blamed wrongly now. If we go to 2.5, if you break the soil up, anytime you do any agriculture operation, you are in essence doing some type of a grinding.
If you do some type of grinding, there's going to be more small particulates. I don't think you can get around that. Agriculture is then going to be blamed.
And it's the same reason that they go out and they essentially try and say where it's coming from. They don't measure where it's coming from. They try and say.
Well, agriculture is a big scapegoat in a lot of areas simply because it surrounds us. Agriculture is there. It's easy to pin the blame. And it's incorrect.
Why USDA? I can't answer that. I don't work for the USDA or with them on this. Maybe it's political. I don't know why they're not willing to say.
Because I think there's enough evidence that there is a problem with these equations. There's been other research showing that there's problems with these equations.
And why they're not willing to say, ''Well, there's a problem.'' And if this goes on, it could get worse and probably will in terms of how much will be blamed on agriculture
Page 92 PREV PAGE TOP OF DOC Mr. SCHAFFER. Thank you, Mr. Chairman.
Mr. COMBEST. Mr. Smith.
Mr. SMITH of Michigan. How large is 2.5 microns? When I made coffee this morning, I've got a fine filtered gold screen so you don't have to put the paper filter in. Would a 2.5 micron go through that?
Mr. PARNELL. Let me answer that question. If you have a bag filter that is supposed to be able to capture particulate, very small particulate, the typical opening on a bag filter is 74 microns.
The diameter of the hair on your head is about 70 microns. The thickness of this paper here is in the neighborhood of 30 microns.
Mr. SMITH of Michigan. So, the answer is yes, it would have gone through that gold screen?
Mr. PARNELL. Yes.
Mr. SMITH of Michigan. If I put the paper filter over the gold screen, it would have gone through that too?
Mr. PARNELL. Yes.
Mr. SMITH of Michigan. And, Dr. Parnell, I might say that I'm sort of intimidated asking questions to such an expert panel. And I really want to add my thanks for all of you being here and taking this time to help us understand.
When we talk about agriculture, I thought, Mr. Isom, I heard you say that a large part of the suspected problem is the exhaust from machinery, from the gas and diesel tractors.
What is the potential, for lack of a better word, pollution coming from the engines and the carbon monoxide as opposed to the dust and whatever other process agriculture might impose?
Mr. ISOM. At this point, it's still difficult to address. That's one of the issues is we just don't know. But when you talk about PM2.5 as these gentlemen have mentioned, it's the secondary pollutants that are really the ones that drive PM2.5. And in the case of diesel engines----
Page 93 PREV PAGE TOP OF DOC Mr. SMITH of Michigan. What does secondary mean?
Mr. ISOM. Do you want to define that a little better than I can?
Mr. FLOCCHINI. In terms of pollutants, they usually define primary pollutants as those that come from a specific source as they would be measured in the atmosphere, carbon monoxide, oxides of nitrogens.
The best example of a secondary pollutant, and that is one that is made in the atmosphere, would be ozone. Ozone is not emitted directly. It is the byproduct of what comes from your automobile and light.
And the oxides of nitrogen that come from your automobile, the hydrocarbons that come from your automobile and light all kind of mix together in the atmosphere, and they form ozone.
So, a secondary product would just in general be something that's kind of made in the atmosphere from other constituents that are there.
Mr. SMITH of Michigan. And so back to sort of the question of the tractors and the machinery and that exhaust as a contributor, and I'm talking strictly on agriculture now, as opposed to the disc and the dust, and it's already against the law that pesticides can't go off the property, help me understand what the potential problem here is for agriculture if this regulation goes ahead and they impose the regulation to the full effect.
Mr. ISOM. The oxides of nitrogen and oxides of sulphur emissions that come from diesel combustion or gasoline combustion form ammonium nitrates and ammonium sulfates which are the secondary particulates that we see in the atmosphere.
And those tend to drive the PM2.5. And so, that's the connection. Oxides of nitrogen emissions and oxides of sulphur emissions that come from those engines form the secondary particles that drive the PM2.5.
Mr. SMITH of Michigan. So, you're saying, and I heard a figure thrown out of 95 percent. And so, you're saying the big potential, the larger, the greater potential problem is the exhaust from engines?
Page 94 PREV PAGE TOP OF DOC Mr. ISOM. That's what we believe at this time. However, we still have EPA that is still indicating that the fugitive dust is the biggest portion of the PM2.5 inventory.
I think once we're able to address that, we'll be able to say that the real issue is going to be on the engines, but the EPA is still saying at this time that it is the dust part of it.
Mr. SMITH of Michigan. Mr. Barker?
Mr. BARKER. Yes, we've been very much involved with that issue. And there are regulations already in place that started in 1996 and extending to 2008 with three different tier levels that will regulate the NAAQS as well as particulates from non-road diesel engines.
So, that issue has already been addressed by EPA from a regulatory standpoint. Those particulates that are emitted, however, will be a part of the inventory that is out there.
And so, the history has been that they look at this inventory, and they say, ''Well, we've regulated automobiles. We've done this and so forth. We haven't regulated tractors yet. So, we must regulate tractors. They must be the contributor.''
The same thing will be true here. When they do the inventory of the county on particulate matter, they will look at all these sources. And one of the things they'll say, ''Well, we've already regulated automobiles. We've regulated non-road engines. There are a number of sources like fugitive dust from tilling and these sort of things that haven't been regulated. Therefore, we must regulate them first.''
And this was kind of the point I was trying to make a little bit earlier. This process is well down the road from that sense. And the engine emissions are already being regulated.
Mr. SMITH of Michigan. Is there a significant difference between a gas engine and a diesel engine?
Mr. BARKER. In terms of particulates, yes.
Page 95 PREV PAGE TOP OF DOC Mr. SMITH of Michigan. Which would be the greater?
Mr. BARKER. From the diesel.
Mr. SMITH of Michigan. And that's mostly from the secondary?
Mr. BARKER. No, it's primarily because of the nature of the fuel used.
Mr. SMITH of Michigan. And I guess what I've heard you say that should concern this committee is that when EPA decides that the area is non-attainment, not knowing what else to do, their tendency is to find something to do.
And that tends to be what's widespread around them. And so, they're going to start saying, ''Well, for a start, let's lay the law down to agriculture.''
Mr. BARKER. Well, I think take it one step further. The reason I mentioned that the engines are already being regulated is that they will look at this and say, ''Well, the engine emissions, per se, are being regulated already. The alternative now is to regulate the hours of use, the fuel used, which Dr. Coates was talking about earlier, the time of day, the wind direction and all these sorts of things.
And that was what I was making my testimony that although there's a direct cost associated with engines that meet these emission standards, it's the ancillary cost to the farmer of changing his cultural management practice.
It may be even far greater than that. And that's what will be proposed.
Mr. SMITH of Michigan. Thank you. Mr. Chairman, I would just like to conclude by saying that I am concerned with the way Congress has lost its ability to oversee the implementation of the law.
And when we remind ourselves that the only authority for promulgating these regulations is the potential endangerment to the public health and what we really haven't talked about is the extent to which a size of a particular particle does contribute to the endangerment of public health, I just express my concern that I hope one of these days that Congress gets back greater authority to make sure that the laws we pass do not result in regulations that go further than the intent of the law in the first place. Thank you, Mr. Chairman.
Page 96 PREV PAGE TOP OF DOC Mr. COMBEST. Thank you, Mr. Smith. You may not be able to answer this question. This is an assumption on my part.
But if Mr. Smith were able this morning to have a coffee filter, that did not allow a particle larger than 2.5 to penetrate it, I'm presuming that it would hold water, that it would not have gone through, that he couldn't have made coffee. Do you have any idea if that's correct or not?
Mr. FLOCCHINI. He'd probably still be waiting for his coffee.
Mr. COMBEST. I'm going to, without objection, ask to be entered into our record a copy of a letter that Secretary Glickman sent to Chairman Bliley dated March 31, 1997 in response to a request he made and the supporting documents.
[The letter of Mr. Bliley follows:]
"The Official Committee record contains additional material here."
Mr. COMBEST. One of those supporting documents happens to be dated March 10, it's been referred to previously, a memorandum to Secretary Glickman from the Agriculture Air Quality Task Force.
I want to just make a few quotes out of this. This is dated March 10. It's slightly over a month old.
The EPA proposed air quality standards in our judgment are not based on adequate scientific evidence, peer review, and interpretation. Thus we recommend that it is premature for EPA to change the existing standard until scientific evidence is correctly obtained and interpreted. We especially challenge the scientific basis of EPA estimates of agricultural impacts.
Given the current state of inaccuracies and misconceptions within the EPA air quality standards and applications and in the spirit of cooperation, we believe it is imperative that the USDA develop a specific memorandum of understanding with EPA to transfer technical expertise and support for those air quality issues derived by the Clean Air Scientific Advisory Committee would significantly involve or impact the agricultural industry.
Page 97 PREV PAGE TOP OF DOC Agricultural scientists possess the knowledge to provide this expertise which will maintain the USDA confidence and integrity among the agricultural industry producers.
We found that many current agricultural air quality issues beg for additional understanding and knowledge well beyond that which exists today.
I think it's important that areas that of which you are talking in regards to making for certain that this is based upon good science, based upon the fact that recommendations would in fact have a cure rather than a harm.
Agriculture is being blamed a great deal for its contribution to air quality. What I wonder is, are they getting any credit? My question is this.
Sure, during a period of time of land preparation or planting, you're going to have more dust stirred up. You're going to have equipment in the fields.
What happens during those months that that crop is on that field and is helping hold the land and keeping dust from entering into the atmosphere?
And what would be the result if complying were so stringent that a person couldn't afford to go out there with that equipment and prepare the land and plant on it? What would happen in its natural state?
I think it ought to be looked at. I have a feeling that the impact on the atmosphere on the air quality would probably be worse if nothing were being done to that piece of property. And I hope that they look at it overall in an average.
I think you brought this up initially in your testimony where you mentioned that this has to be over a range or period of time. There may be a period in which you're exceeding.
But there is, I would suppose, and I would hope that science could shed light on this, that in fact overall we're better off because of that than worse off because of that. I don't know whether you have any comments to make or not.
But I don't think agriculture is getting the credit for the good that it is doing.
Page 98 PREV PAGE TOP OF DOC Yes, sir?
Mr. BARKER. Mr. Chairman, when we got started on regulating the engines for non-road equipment and we started trying to build the inventory and EPA and others did too to evaluate this, we pointed out the fact at that particular time that in the previous 10 years the amount of fuel, gas and diesel, that was used in agriculture had been reduced by 30 percent.
And we felt that this was a significant contribution to improving the air quality. Their view was, ''That doesn't count. It's what you're doing now that we have to regulate.''
So, I'm afraid we're not going to get much credit on that side. And that is extremely frustrating because that is not a pure and fair test of actually what is occurring.
Mr. COMBEST. We may be back to the period Mr. Schaffer was referring to before there were people. There were a lot more buffaloes, and they weren't wearing diapers at that time.
I don't know how much of an impact that has versus now, but that's the concern that we have is that this is not being objectively viewed.
Mr. BARKER. But my first point in my testimony was that the regulators are in business to regulate. Where you get this balance, I assume has to come from Congress in the way the laws are constructed and oversight.
Mr. COMBEST. Balance and logic and passing the stupidity test is something we want to start putting legislation to before it becomes law. I want to say because this hearing has not done justice to the testimony that you all have submitted, this is extremely helpful.
It is extremely technical. And I realize this took a great deal of time. It may not have taken as much time to put it together, but it has taken a lot of time to compile this information.
And I would certainly commend it to all of the members of this subcommittee and full committee, and it will, as was indicated, be a part of the record. And we have stayed away from that somewhat intentionally.
Page 99 PREV PAGE TOP OF DOC But the information you have provided from the technical aspect is very much appreciated. And as I said, was certainly not done justice in this hearing. Mr. Schaffer, do you have additional questions?
Mr. SCHAFFER. I do, Mr. Chairman, have one more question. This whole initiative, as Mr. Dooley pointed out, seems to be based on the notion that reducing the particulates in the atmosphere is somehow going to save lives.
And the EPA is throwing numbers out on the table, 40,000 premature deaths in the United States each year, that going to 2.5 the EPA says will save 15,000 lives.
And so, first it's remarkable to me how they arrived at such a figure in the first place upon which to build an entire policy agenda. We mentioned some of these other events, volcano eruptions, forest fires, and so on.
If you use the logic that underlies, the premise, that underlies the initiation of these new standards, would it be reasonable for us as policy makers to look for the evidence that after Mt. St. Helen's, for example, that a certain number of people died that was associated directly with that event?
Or after a forest fire erupts that downwind a certain number of people will die as a result of that? Are these reasonable questions for us to ask since that seems to be the basis for this policy in the first place?
Mr. PARNELL. Let me give it a shot, Mr. Schaffer. And let me qualify my response by saying that I'm an engineer. And I was critical of that data for engineering reasons and not in comparison with emissions from Mt. St. Helen's.
But in looking at the engineering aspects of the studies that were used to develop the 20 to 40,000 lives would be gained, one of the things that they're proposing to do is change the concentration from mass per standard volume to mass per actual volume.
This is somewhat technical, Mr. Combest. And I'm going to try to explain it like an aggie professor so you might understand this. Mass per standard volume versus mass per actual volume.
Page 100 PREV PAGE TOP OF DOC The reason why they did that is they said in the studies they determined this is the physicians and the health specialists who did the studies that they could detect no differences in the exposure in Denver, CO versus Philadelphia, PA at sea level, Denver at 5,000 above sea level.
Well, as an engineer, I know that the air density in Denver is significantly less than it is at sea level. In fact, it's about .06 pounds per cubic foot versus .075.
Well, as a simple calculation shows that at the same level, at 150 micrograms per actual cubic meter that a person in Denver is going to be exposed to 20 percent more pollutant than somebody in Houston or in Philadelphia.
Twenty percent more. But the epidemiology studies were not able to detect any differences. That implies to me that the sensitivity of the studies, something was wrong with the studies.
Now, the other issue here is when you look at the NAAQS, they're saying they're going to go from 150 micrograms per cubic meters, PM10, down to 50 micrograms per cubic meter, PM2.5.
The only way you can assume saving lives there is overnight you have a change in public exposure to this. It's not going to happen that way. The system doesn't work that way.
EPA establishes the NAAQS. The States do their sampling, attempt to comply with the NAAQS, put more and more controls on to lower public exposure.
But if public exposure is not lowered, and if we go forward, if EPA goes forward in July of this year and does this thing, and 5 years from now we still have the same problems that we had in 1997, it seems to me it would be appropriate for the public to come back and ask for an accounting from EPA and from Congress.
We've imposed all these controls. We drove a number of small businesses out of business. And we didn't change public exposure levels. That's the position we're in right now.
One of the difficulties as a testifier here, and I'm looking at Congress here, is what's going to happen? I'll be honest with you, folks. In talking to my graduate students at A&M, ''What's going to happen, Dr. Parnell? It doesn't make any difference what you say to the Congressmen up in Washington. There's going to be a PM2.5 in July. It's going to happen.'' Is it going to happen?
Page 101 PREV PAGE TOP OF DOC Mr. COATES. I'd just like to make a comment in regards to this analysis. You probably could prove that there was deaths due to the Mt. St. Helen's eruption.
And it's a question of what you include in the analysis. And this is some of the problem with these health studies that are going on. You can choose to include everything, or you can choose to include certain parameters in the analysis.
And then, you can use statistics to make--and basically by playing with data, you can almost show black is white. And this is some of the problem with these studies that are going on.
I'm not in the health field, but in discussing and looking at some of them, how complete are they? What all was considered in the analysis that these truly are an effect of the particulates, the PM2.5?
Or is it being influenced by something else that's there? And that's why I go back to say you could probably show from Mt. St. Helen's in some communities there was. And it may be true, and it may not be true depending on how you manipulate the data.
And I think this is something that we have to be clear on. EPA has chosen to accept certain things. I'm not sure they're scientifically founded, based.
Mr. FLOCCHINI. I just want to add a little bit to that. The trouble I have, Mr. Schaffer, with statements like 40,000 deaths and 15,000 can be saved if we went to 2.5, if we're not measuring 2.5 currently, how do we know--we don't have a baseline.
And so to make these, and it goes to what Dr. Coates was just saying, what parameters are being used? We're not measuring 2.5 currently. We have no historical record. So, how can we make that statement?
To followup, I think one of the classic studies, in fact, probably our Federal Standard is based on the London data in 1952. There were something like 4,000 deaths beyond what's expected during a 1-week period.
And particulate matter utilizes one of the parameters. Now, it was particulate matter probably something like 60 microns and less. But was it the particulate matter itself, the total mass? Or was it some constituent of that particulate matter?
Page 102 PREV PAGE TOP OF DOC We don't know those answers. If I was living next to an arsenic plant, would I be worried about the particulate matter or the amount of arsenic that I was breathing? Arsenic would be a particulate.
But I'd be more worried about the concentration of arsenic I believe than the total mass. Those are the kind of questions, I think to followup with what the other panel members have said, that have to be asked when we look at these kinds of statements.
Mr. BARKER. Mr. Chairman, if I might just suggest. Mr. Schaffer, at the conclusion of the documents we submitted, the last one was included to address in part your question which was from a Tony Cox who appeared at the Salt Lake hearing, EPA testimony, where he rather succinctly I think addresses these kinds of questions that you've raised in challenging the efficacy of the conclusions that EPA came to.
And I would just refer you that as a quick and useful insight to the issue.
Mr. COMBEST. I think Dr. Parnell's students are correct. And that is a concern. It's not always based on--even when you have good science to make an argument, that has not always in the past kept the Government from doing some things that wouldn't pass the logic test.
And my first experience in this was on the staff in 1971 of a United States Senator from Texas. And shortly after that, the Delaney clause allowing no tolerance of pesticide in food, zero tolerance, was imposed.
And one of the concerns that Texans had at that time, put a little implant in the ear of cattle and feed, DES, diethylstilbestrol. And the only organ in a cow that ever showed any DES residue was in the liver.
And it was taking something in the neighborhood of 4,000 pounds a day that a person would have had to ingest of liver to get that dosage. And not many people ate that much.
But the same argument, alar in apples. It's a fear thing that drives so much of this. And it's not based on logic and good sense. And that's what we're trying to return.
Page 103 PREV PAGE TOP OF DOC Fortunately, in the last Congress after 25 years of studying the issues, the Delaney clause was changed. And it was only 25 years too late in coming.
But that is the fear is that you get on the idea of it, and it makes it very difficult, even with sound argument, to derail that train. But your participation has been extremely beneficial.
And it is something of great concern to all of us. And I would just like to once again thank you all very much for taking your time and for coming up here and for the participation that you've had. The hearing is adjourned.
[Whereupon, at 1:15 p.m. the hearing was adjourned, subject to the call of the Chair.]
[Material submitted for inclusion in the record follows:]
STATEMENT OF ROGER A. ISOM, CALIFORNIA COTTON GINNERS AND GROWERS ASSOCIATIONS
I am Roger Isom, director of technical services for the California Cotton Ginners and Growers Associations, which represent all of the over 100 cotton gins and over 2600 cotton growers in the State of California. My comments presented here today, will focus on the proposed ambient air quality standard for PM2.5, and its impact on the agricultural industry. The impact we have experienced attempting to meet the PM10 ambient air quality standard, has given us plenty of reasons to know that we can't jump immediately into a new air quality standard we know so little about. It is an absolute necessity to allow the science surrounding PM2.5 to develop, so that intelligent, reasonable, and justifiable decisions can be made.
The agricultural industry's primary issue with attempting to achieve attainment of the PM10 standard has been the haste to have industry comply with fugitive dust rules and regulations. Because fugitive dust from tractors is so highly visible to the general public, the agricultural industry has spent the past 5 years expending tremendous amounts of time and money to verify the necessity to move forward with fugitive dust rules and regulations for reducing PM10. The ambient air quality standard for PM10 was established before measurements were performed on emissions sources to determine who the predominant sources were, and what could be done to reduce those emissions. Many onerous requirements were proposed, including no-till days, no-spray days, water sprays on the back of discs, and air pollution permits for farming operations. New information, developed over the past couple of years, now indicates that these control measures may have done little, if anything, to reduce ambient levels of PM10. We must not make the same mistake on PM2.5. Time must be allowed for the science to make the proper assessment of the problem, before time constraining deadlines are set in stone and industry is forced to waste resources that done solve the ultimate problem.
Page 104 PREV PAGE TOP OF DOCDEFINING THE PROBLEM. In 1987, the PM10 ambient air quality standards were adopted. By 1991, the San Joaquin Valley was classified as moderate non-attainment, which required the San Joaquin Valley to achieve the PM10 standard by 1994. Knowing that the District could not achieve the standard by 1994, the District was forced to adopt Reasonable Available Control Measures (RACM) in 1991. Then in 1994, the San Joaquin Valley was reclassified as serious nonattainment, a designation which forced the District to adopt Best Available Control Measures (BACM). These mandated deadlines have forced some questionable decisions to be made. First and foremost, EPA guidance on how to achieve the PM10 air quality standard was not published until 1992, and this information only focused on windblown dust. In comparing air quality data with meteorological data since 1987, one would find that the exceedances of the PM10 standard occur primarily during low wind periods, and typically there are no exceedances when the wind is blowing. In other words, the EPA proposed control measures would have had very little effect on the PM10 exceedances in the San Joaquin Valley.
It wasn't until 1995, eight years after the PM10 ambient air quality standards were set, that we discovered that, in fact, the San Joaquin Valley has two separate and distinct PM10 problems. One type of exceedance is characterized primarily by geological material, and occurs primarily during the late fall to early winter time period. The second type of exceedance is characterized by PM10 made up primarily of secondary particles, such as ammonium nitrate, ammonium sulfate, and organic aerosols. These secondary particles primarily come from combustion type sources. Because of this secondary aerosol problem, the control measures initially proposed by EPA would not have put the San Joaquin Valley into attainment of the PM10 ambient air quality standard.
Unfortunately, the deadlines were set and the District had no choice but to move forward with adoption of control measures for fugitive dust sources. Agriculture was brought into the picture because of a highly erroneous emissions inventory. Tillage operations were the focus of the initial discussions with the air district. This was due to the fact that information, published by EPA, indicated that alfalfa was disced 8 times per year, rice 13 times per year, and rangeland twice per year. This greatly overestimated the emissions, and made agriculture the prime target. Some of the control measures that have been suggested for agricultural operations include punch planters for cotton, sprinkler irrigation immediately prior to land planing, and water sprays on the back of discing equipment. Also looked at was the use of shaking equipment to shake trucks and farm implements prior to exiting a field or unpaved road onto a paved road. This would supposedly eliminate the carry-out of mud or dirt, which would later be entrained into the atmosphere by cars or trucks traveling on the paved roads. These control measures would have been devastating to the agricultural industry, had they been allowed to be placed into regulation.
Page 105 PREV PAGE TOP OF DOCAt one point it was even discussed that farms should be permitted by the local air districts. In the San Joaquin Valley alone, it was speculated that there would be over 31,000 permits for farms. Each silage pile, unpaved road, and equipment storage yard, to name a few, would have been permitted. The District estimated that they would need 70 additional permitting engineers to process air quality permits for farms.
As I indicated, there has been information used by the air districts that identifies agriculture as a primary source of PM10 emissions. For the past five years, the agricultural industry has fought to address the deficiencies in those inventories. One example is windblown dust emissions from agricultural lands. In the original inventory, it was assumed that all farming in California was dryland farmed. It assumed that the land was not irrigated, and that there was no vegetative cover, or crop canopy, from the crops. Once irrigation and vegetative cover was put into the wind erosion equations, the wind erosion PM10 emissions inventory was reduced an incredible 80 percent, from 410 tons per day of PM10 to less than 58 tons per day of PM10. Another example is the emissions inventory for agricultural tillage operations. There are two major problems identified in this inventory, including the actual number of passes the equipment makes per acre and the PM10 emissions produced from each type of operation, such as discing, ripping, or furrowing. Just by updating the inventory with the current acreage information for each crop and correcting the number of passes per acre for the tillage equipment, the agricultural PM10 emissions inventory for tillage operations was reduced 30 percent from 140 tons per day of PM10 to less than 107 tons per day of PM10. Work on determining the actual PM10 emissions from each operation is just now getting underway.
Probably the most blatant example of an inaccurate inventory, that would have cost the agricultural industry thousands of dollars, was the initial emissions inventory for internal combustion engines used to drive irrigation pumps. The original estimate proposed for the San Joaquin Valley was based on a few interviews with supposed industry experts. This study estimated that the NOX emissions (precursors to PM10) from irrigation pump engines was 626 tons per day. This would be the highest emissions category for NOx emissions in the San Joaquin Valley, exceeding all mobile sources including all of the cars and trucks, which together only emit 353 tons per day of NOx. A new study was commissioned, that was based on actual interviews with over 360 farmers. The new study also reflected updated engine emissions information. This new study determined that NOx emissions from irrigation pump engines is only 32 tons per day of NOx.
Page 106 PREV PAGE TOP OF DOCConsidering all of these discrepancies, it is unbelievable that we are now faced with the same problems with PM2.5, by considering to move forward with the adoption of a new standard at this time. Based on the 1994 Emissions Inventory for the National Particulate Matter Study, fugitive dust emissions from agriculture have been listed as the third largest source of PM2.5 nationwide, falling below paved and unpaved roads. This is hard to believe, since there has never been any actual PM2.5 emissions data taken on agricultural tillage equipment, using an EPA approved PM2.5 sampler. Furthermore, this inventory only provides estimates for directly emitted PM2.5, not the secondary form of PM2.5. This includes as ammonium nitrate, ammonium sulfate, and organic aerosols, which are formed in the atmosphere and have been shown to make up the majority of the PM2.5 measured in the San Joaquin Valley. This only emphasizes the necessity to fully study PM2.5, before deadlines are set and rules are developed.
Another area affected by a possible PM2.5 ambient air quality standard is pesticides. California is already under a mandate to reduce volatile organic compound (VOC) emissions from pesticides by 20 percent by 2006. The original draft regulation proposed a 45 percent reduction. In setting that goal, the California Air Resources Board could not provide and did not know how much VOC emissions were produced by the application of pesticides. This was originally proposed in the Ozone state implementation plan (SIP). Now, the San Joaquin Valley Unified A.P.C.D. has proposed to include this control measure in the PM10 SIP, even though the District isn't able to quantify the pesticide VOC emissions contribution to the formation of PM10. This excludes the fact that few pesticides were even applied during the late fall and winter months, the time at which most exceedances of the PM10 standard occur. This means that agriculture may be forced to reduce pesticide emissions even though they may not reduce the ambient PM10 levels.
EPA is also looking at oxides of nitrogen (NOx) and ammonia (NH3) emissions from soils as contributors to ambient levels of PM10. This could mean that farmers will also have to address the application of fertilizers as an air quality concern. Yet, recent studies performed in the San Joaquin Valley indicate that there is very little NOx and NH3 emissions from the soil.
Page 107 PREV PAGE TOP OF DOCTHE COST IMPACT. Since minimal information is currently available to accurately determine the extent of the agricultural portion of the PM2.5 problem, it is hard to estimate the cost impact that the new standard would have on the agricultural industry. Obviously, the control measures listed previously in this testimony would have significant impact on the agricultural industry. For example, if the cotton industry were forced into using a punch planter to plant cotton, not only would we face a tremendous initial capital expenditure, at 50,000 seeds per acre we would never be able to plant all the cotton in a timely manner.
One area we can comment on is reformulated diesel fuel. California has adopted a diesel fuel formulation standard to reduce emissions of NOx, SOx, and PM10, that is more stringent than any diesel fuel standard in the country. Unfortunately, it is extremely costly for refineries to retool to produce this new fuel. As a result, the number of refineries producing the new diesel fuel have been reduced from 36 in 1988 to only 13 in 1996. This has changed the supply and demand in California, from one of oversupply to one of supply barely covering demand. This has meant increased fuel cost for diesel users in California, creating an economic disadvantage for California farmers. A disadvantage that has led to disaster for many California farmers. These types of decisions must be thought completely before they are implemented. We believe that diesel will be affected nationwide with the new PM2.5 standard. With that in mind we would expect to see the cost of the new refining equipment being passed on to the diesel users.
We also believe that the new standard will significantly affect the food and fiber processing industry. As an example, we believe that cotton gins will be forced to install lo-NOx burners. These burners currently cost approximately twice the amount of conventional burners, yet California is already looking at requiring these to be installed under the current Ozone and PM10 standards.
THE SOLUTION. In attempting to resolve some of the previously mentioned issues, it became necessary to conduct a multi-year, multi-faceted air quality study. Such a study was developed and is now underway in California. This study, known as the California Regional Particulate Matter Air Quality Study (CRPMAQS), will address all areas of the PM10 and PM2.5 issues. This includes emissions determinations and quantification, data analysis, demonstration studies, ambient air quality measurements, and model development. USDA is playing a major role in this study, by helping to fund emissions studies on agricultural operations. Once completed, it will be the most thorough, most complete particulate matter air quality study ever conducted in the world. It will be the source by which decisions, with regards to particulate matter, will be made in California, and will serve to aid other areas in the nation and world in their particulate matter decision making process. This study and others like it must be completed before attainment deadlines and regulations are set in place.
Page 108 PREV PAGE TOP OF DOCThe Agricultural Air Quality Task Force, under USDA, is another avenue by which intelligent decisions can be made, with regards to research, proposed control measures and policies. Their review is necessary, as it will ensure the necessary science, peer review, and interpretation, needed to develop feasible and justifiable regulations and control plans for attaining the PM2.5 air quality standard.
In closing, I want to reiterate that much work is yet to be done before moving into the setting of a new standard for PM2.5 and all of the requirements and deadlines that come with the setting of that standard. We must develop an accurate measurement method for PM2.5, in order to determine and quantify the significant sources of PM2.5, and we must complete the necessary research to understand the true nature of PM2.5 and what contributes to its formation. We must also continue research to determine what constituents of PM2.5 actually cause the supposed health effects that are referenced in the recent health studies. A shotgun approach will only serve to put American agriculture out of competition with other countries, and put agricultural producers out of work. Agricultural commodities tied to a world price can not simply pass on the cost of doing business to the consumer. Therefore, any increase in the operational costs of farming is significant and must be based on accurate information that justifies the expenditures. The agricultural community wants to breath clean air as much as anybody, yet doesn't want to waste money on control measures that have little or any effect on cleaning up the air quality in this nation. We would recommend that it is too premature to set forth a new air quality standard until the science has caught up and intelligent and reasonable decisions can be made in achieving that new standard. As George Wolff, chairman of EPA's Clean Air Scientific Advisory Committee (CASAC) stated, ''in many cases NOx, SOx, or carbon monoxide can be as important, and in some cases more important than PM in describing mortality''. If this is the case, why should into PM controls at this point.
On behalf of the cotton growers and cotton gins in the State of California, I appreciate the opportunity to speak before you and provide you with the experiences we have faced in the air quality arena. Hopefully, these experiences demonstrate the necessity to delay the setting and implementation of the PM2.5 ambient air quality standard, and to move cautiously before any mandated deadlines are set forth.
Page 109 PREV PAGE TOP OF DOCTESTIMONY OF JAY J. VROOM, AMERICAN CROP PROTECTION ASSOCIATION
Mr. Chairman, thank you for the opportunity to submit comments for the record for the Subcommittee hearing on air quality held on April 23, 1997. I represent the American Crop Protection Association (ACPA), a not-for-profit trade organization of U.S. manufacturers, formulators and distributors of agricultural crop protection and pest control products. ACPA's membership is composed of the companies which produce, sell and distribute virtually all of the active compounds found in crop protection chemicals registered in the United States.
EPA'S PROPOSED PM2.5 IS OF GRAVE CONCERN FOR AGRICULTURE
The EPA recently proposed major revisions to particulate matter standards established under the Clean Air Act-mandated National Ambient Air Quality Standards (NAAQS). The proposed new standard, designed to remove miniscule particles 2.5 microns or less from the air, is of grave concern to agriculture and agribusiness. In addition to the fact that the agency has yet to produce convincing peer-reviewed scientific studies that show justification or even the practicality for such overly stringent measures, a PM2.5 standard would force excessive and costly burdens onto farmers and agricultural industries. The benefits of this proposed change are unclear at best. States, especially in the West, clearly are still struggling to comply with the comparatively easier to achieve PM10 standards.
Adoption of the more stringent PM2.5 would lead to dramatic increases in the costs of agricultural production. This in turn would result in significantly higher national commodity prices, thereby placing America's farmers at a distinct competitive disadvantage to foreign growers. Additionally, how long before higher commodity prices will impact on the price of food on our kitchen tables?
MODERN FARM PRACTICES ARE AIR AND EARTH FRIENDLY
Page 110 PREV PAGE TOP OF DOCAgriculture already is engaged in environmentally responsible programs. American farmers and their supporting agribusiness industries have come a long way from the Dust Bowl era, and now engage in environmentally-sound farming practices. Enormous progress has been made in controlling fugitive dust production and wind erosion of soil. Widespread and growing use of conservation tillage and no-till practices by farmers are providing environmental benefits and helping maintain the productivity of our farmland by minimizing both air and water erosion of topsoil. For example, leaving last year's crop residues on the soil surface with reduced or no tillage helps conserve soil structure and organic matter content, protect the quality of nearby water bodies and establish wildlife habitat.
Modern tillage practices are highly significant examples of how farmers are greatly reducing dust emissions. Conservation tillage leaves at least 30% of the soil surface covered with crop residue prior to planting. No-till is a form of conservation tillage where no seed bed preparation is performed prior to planting. Both practices utilize herbicides to control weeds and conserve moisture. In contrast, conventional tillage aggressively stirs the soil's top layer, thus mixing any crop residue with the soil. Conventional tillage also demands additional passes across the field to smooth the surface and control weeds, thus pulverizing the top-soil structure and making it more susceptible to wind erosion.
Some additional facts that show agriculture is already successful in proactively addressing air pollution concerns:
Conservation tillage and no-till were used on nearly 150 million acres in 1996 - roughly equivalent to half of America's farmland! According to the Conservation Technology Information Center, this number is up by 30% from 1989, and continues to grow.
According to the USDA Natural Resource Conservation Service's (NRCS) Wind Erosion Equation, no-till has resulted in up to 80 percent reduction in soil losses.
Page 111 PREV PAGE TOP OF DOCAccording to the same Wind Erosion Equation, conservation tillage methods resulted in up to 60 percent reduction in soil losses.
With more than half of all farmland (and most of the highly erodible land) protected in this manner, these conservation methods form the backbone of several Federal conservation programs, including the Conservation Compliance Program and the Environmental Quality Incentive Program.
ACPA MEMBER-COMPANY PRODUCTS ARE AN ADDITIONAL AID TO FARMERS' SOIL CONSERVATION EFFORTS
The member companies of ACPA produce herbicides that are an integral component of conservation and no-till systems of crop production. Farmers using conventional tillage practices often try to enhance yields by relying on periodic tillage for purposes of weed control. Under the no-till and conservation tillage practices, herbicides offer a reduced-dust alternative to control unwanted vegetation and play an important role in meeting air quality standards in agricultural production areas.
ACPA and its member companies will continue to work with farmers to acquaint them with the environmental and economic benefits of conservation tillage and no-till, and to help answer their questions about air and water quality protection.
In short, we urge the United States Congress to oppose lower air particulate matter standards. Agriculture already has made tremendous advancements in environmentally-sensitive farming methods, and these voluntary practices should be permitted to continue to accomplish further improvements in controlling particulate matter emissions. The new arbitrarily proposed PM2.5 standard not only is unjustified and unnecessary but would impose substantial expenditures on U.S. agriculture that would place American growers at a competitive disadvantage to their counterparts in other countries.
Page 112 PREV PAGE TOP OF DOC "The Official Committee record contains additional material here."