Animal Feeding Operations Emission Estimation Methods: U.S. Environmental Protection Agency Office of Inspector General Report

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued a September 19th report titled:

Eleven Years After Agreement, EPA Has Not Developed Reliable Emission Estimation Methods to Determine Whether Animal Feeding Operations Comply With Clean Air Act and Other Statutes (“Report”)

See Report 17-P-0396 (September 19, 2017).

OIG states that it undertook a review to determine what actions EPA has taken to evaluate air emissions from animal feeding operations (“AFOs”). The evaluation included an assessment of the status of the National Air Emissions Monitoring Study (“NAEMS”). The industry-funded NAEMS and EPA’s analyses of the study’s results are stated to comprise the agency’s primary actions to evaluate air emissions from AFOs over the past decade.

The NAEMS was stated to have been completed more than seven years ago. However, OIG concludes that EPA has not finalized the emission estimating methodologies for AFOs. Further, it states that the federal agency has only drafted methodologies for about one-fourth of the emission source and pollutant combinations study.

EPA is stated to have projected that the emission estimating methodologies would be developed and published by 2009. The importance of such methodologies is their utilization by EPA, state and local agencies and industry operators to determine the applicability of the Clean Air Act and other statutory requirements.

The OIG Report recommends a number of actions EPA can take to address the cited issues.

A copy of the OIG Report can be downloaded here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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