Livestock producers face new EPA reporting requirement

By Herald-Whig
Posted: Nov. 16, 2017 8:35 am Updated: Nov. 16, 2017 1:31 pm

PITTSFIELD, Ill. -- John McIntire met a Wednesday deadline for a new air emissions report -- even without knowing much about the latest requirement from the U.S. Environmental Protection Agency.

As a result of an April 11 federal court decision, EPA issued a notice Oct. 26 directing all livestock farms emitting more than 100 pounds of ammonia or hydrogen sulfide in a 24-hour period to report continuous air emissions under the Comprehensive Environmental Response, Compensation and Liability Act, or CERCLA. Most farms had been exempt from CERCLA reporting.

Using a spreadsheet developed by University of Illinois Extension, "the reporting upfront appeared fairly easy, but I don't know what it means for down the road," said McIntire, owner and general manager of Pike Pig Systems. "It's a new situation for us."

McIntire expects the requirement to affect a large group of producers.

"Just by doing the spreadsheet, it appears it's going to affect the majority of operations in the area. Judging by the size of our operations, one was fairly small, and it came under the regulations," he said.

Reports emailed to the National Response Center included the name and location of the farm along with the amount of ammonia or hydrogen sulfide released, listed as greater than or equal to 100 pounds, the Illinois Pork Producers Association said in materials provided to producers. An automatic response email included a single identification number for the farm to include in a follow-up written notification report to the EPA Region 5 office within 30 days.

Extension developed web calculators to help farmers estimate daily emissions by livestock type. "It's the best estimate that our farmers can use," said Jennifer Tirey, executive director of the Pork Producers Association. "However, the calculations are based on EPA numbers that are nearly 10 years old, so it is very hard for anyone to set a specific threshold number or know if the number is presently accurate."

By using the animal numbers in the spreadsheet, a farmer can determine whether reporting action is required.

For example, a grow-finish swine farm that uses deep pits for manure storage and has fewer than 2,703 head or a turkey grower with fewer than 12,970 tom turkeys raised from 36 to 140 days old would not need to take any action.

For most cases, emissions of ammonia, rather than hydrogen sulfide, will be the greater value on farms.

Farmers that signed up and participated in EPA's Air Consent Agreements, which remain in compliance with those agreements and have not been expanded, are not expected to report emissions.

EPA sought more time to delay the effective date to develop guidance materials to help farmers understand the requirement, but the federal court took no action, which meant many farmers had to rush to comply.

"I'm sure many producers out there don't know it," McIntire said. "I would not have known it without IPPA and Farm Bureau."

More information about the reporting requirements under CERCLA is available by calling the Pork Producers Association at 217-529-3100 or going to To download a table showing reporting thresholds, type "" in a web browser.

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