Thursday, March 10, 2011
Dust in the Wind
The meeting is part of a mandatory 5 year review and deemed a listening session to take comments back to the EPA director in Washington, D.C. regarding agriculture dust. I did not stutter my writing...agriculture dust.
I want those in agriculture to know that they were well represented at the meeting by farmers, ranchers, organizations, and researchers. There were folks on the phone as well that had gathered in Boise to take notes and provide comments. How effective we will be is up to the whim of the EPA Director.
The gist of dust regulation is to examine the existing 24 hour standards for PM 10, or "coarse" particle pollution. PM 10 is for particles 10 micronmeters in diameter and smaller that had been set at 150 micrograms per cubic meter of air since 1987. The EPA is also looking at standards for PM 2.5 which is fine particles. All of this is under the clean air act and I am sure you understood completely what you just read.
The background information was presented to us by the EPA person brought in for this meeting from back east. He went through his PowerPoint presentation and explained the different formulas and procedures that are used for calculating days that violate the standards. (Now I am keeping things simple and not naming names because we have to work the problem at this point.)
Unless you are a scientist that studies air and calculates whether the EPA's standards are being met, you will have a glassy look in your eyes like the majority of people representing ag had. The "alternative standards" that EPA is looking at is called "the 98th percentile form."
Their fact sheet defines that as: "Using that form, an area would meet the standard if the 98th percentile of 24-hour PM 10 concentrations in a year, averaged over three years, was at, or below, the level of the standard. EPA staff also have concluded that the science could support revising the standard, in a range of 65 to 85, but only if the form of the standard is also changed." Now I am sure that this cleared things up for you. Don't feel bad, it took several times for everyone to understand it too.
The skinny of things is that EPA needs to review air standards every 5 years. There is a cutoff date for scientific studies to be used for review purposes. However, the one thing that was very clear to me, like a summer day in north Idaho, was the science is not conclusive.
Everyone there heard dozens of times from the EPA person heading the meeting and their expert standing by on conference call use the terms "What if," "Not conclusive," and "Uncertain." And we are talking about the science they are using to do the regulations and proposed revisions.
The science, along with the 98th percentile garnered chuckles from the crowd and eye rolling to be envied by a hot tempered mother cow that just gave birth. What I took from the dialogue exchanged was EPA wants to cut the standards in half, add a complicated formula, and more cities would have fewer days of violations.
My math skills are not the greatest, but I did learn in Kindergarten that if you make half the money you did before, things would be tougher to do than easier. EPA math, I gathered from that meeting, states otherwise. Are you getting a warm and fuzzy feeling yet?
The head EPA person also stated that we have to go through this regulatory process. There are procedures in place to ensure that things are done by the book regarding air standards. But what about the EPA? Are they supposed to follow proper protocol?
Is the EPA following the highest law of the land, the Constitution? Have their rules been proposed, debated, and passed by Congress or is it the whim of one person? I also heard the term executive order! That is a lot of control over tens of millions of people to be based upon inconclusive science by one person.
The ag people around the table asked unanimously to keep the standards where they are. When common senses was brought up by the EPA person, I asked him to add economic impacts as consideration for clean air instead of health as the only factor.
And if health is the only factor, what about the kids and people that would be malnourished or die in just our country alone if agriculture was not able to create some dust. What about suicide rates climbing even higher in rural areas when a farmer is told to close the doors after 100+ years of operation and can't handle it? Is that a health concern?
Common sense tells me that farming is an industry like no other, dirt is involved. It takes dirt to grow food to eat or feed animals that also live on dirt. In Idaho, the highest percentage of road miles are gravel which creates dust. Will the federal government sue my local highway district because there is not enough money to pave all of those road miles they are in charge of to limit dust? I think less regulation would be the common sense approach.
I am proud to say that I and others like me represented not only agriculture at the table, but the rest of the population and America. We asked tough questions and were direct in saying leave the standards where they are. How is that for common sense?