Think Out Loud

Nearly two dozen advocacy groups call on Oregon to regulate emissions from large dairy farms

By Sheraz Sadiq (OPB)
Sept. 23, 2022 12:18 a.m.

Broadcast: Monday, Sept. 26

Last month, 22 environmental, public health and animal welfare advocacy groups sent a petition to the Oregon Environmental Quality Commission calling on it to regulate air pollution from large dairies. The petitioners want the state to require dairies with 700 or more cows to obtain an air emissions permit and conduct an air impact assessment of pollutants like methane and ammonia. They also claim that regulating emissions from large dairies is necessary for Oregon to comply with the federal Clean Air Act and meet the state’s greenhouse gas reduction targets. But the Oregon Dairy Farmers Association claims that the regulations aren’t necessary and would impose an additional financial burden on dairies which are already struggling with inflation and overtime pay requirements for farmworkers.

Joining us are Alice Morrison, the organizational director of Friends of Family Farmers, an advocacy group that signed the petition, and Tami Kerr, the Oregon Dairy Farmers Association executive director.


The following transcript was created by a computer and edited by a volunteer:

Dave Miller: This is Think Out Loud on OPB, I’m Dave Miller. Last month, 22 environmental public health and animal welfare advocacy organizations sent a petition to the Oregon Environmental Quality Commission. They’re asking it to regulate air pollution from larger dairies. The petitioners say this regulation is necessary for Oregon to comply with the federal Clean Air Act, and meet the state’s greenhouse gas reduction targets. But the Oregon Dairy Farmers Association claims that the regulations are not necessary, and would unduly burden farmers. We’re going to hear from the head of the Oregon Dairy Farmers Association in about 10 minutes. But first, Alice Morrison joins us. She is the organizational director of Friends of Family Farmers. That’s an advocacy group that signed the petition. Alice Morrison, welcome.

Alice Morrison: Thank you for having me.

Miller: What is the problem that you are hoping to solve?

Morrison: Large dairy operations emit a number of dangerous air pollutants, including ammonia, hydrogen sulfide, particulate matter, volatile organic compounds, and climate altering pollutants like methane and nitrous oxide. And up until now, there has been no regulation on air emissions from dairies. In 2008, the Dairy Air Task Force was commissioned by the Oregon legislature. That was a bipartisan and industry inclusive group that outlined the same measures that we’re requesting now to protect Oregon’s air quality for community health and to reduce greenhouse gas emissions. But nothing has been done in the 15 years since those recommendations were made. This program is targeted on the industry’s largest polluters, and provides a framework to quantify emissions, and have these facilities apply right sized management practices to reduce them. For larger polluters, obviously more robust best management practices are necessary. But for smaller operations, these management practices could be as simple as covering feed piles and silage with weatherproof tarps. The problem of the dairy air emissions task force that was convened in 2008 was urgent enough for them to take that action 15 years ago, yet nothing has been done since. So it’s time for Oregon to come into compliance with federal Clean Air Act requirements and move into a more climate resilient agricultural future, centered on accountability.

Miller: How much do we know about the amounts of all those different gasses, whether they would be pollutants that could endanger human health, or say methane, a very powerful climate changing gas. How much do we know about the levels of those that are currently going into Oregon air right now?

Morrison: According to the Environmental Protection Agency, livestock production is the dominant source of methane in the United States. And manure management is the fastest growing major source of methane, with total emissions increasing more than 62% between 1990 and 2020. According to this research, dairy operations specifically are a large part of these increases in manure methane emissions, with overall dairy emissions increasing 122% in that same time frame. In Oregon, agriculture is the leading source of methane emissions and animal agriculture is responsible for over three million metric tons of CO2 equivalent each year.

Miller: What exactly do you want the Environmental Quality Commission to direct DEQ to do? What would you like to see as the practices of these dairy farms?

Morrison: This is a permitting structure that we want to put in place. It would apply to new dairies that are looking to come into existence, or expand existing dairies who currently hold large CAFO permits in the state.

Miller: Meaning 700 head or more, is that right?

Morrison: Yes, that’s true. And so there’s two parts to this permitting process. The first is to quantify the emissions from each dairy. And there are systems in place outlined in the petition, and we have reference points in states like California who have systems like this for us to look to and use where you can quantify the emissions coming from your facility. And then based on that, there’s a list of suggested best management practices that can be employed to eliminate some of those emissions and bring them within more manageable levels. In the realm of feed storage, it could be storing grain in weatherproof structures or under weatherproof coverings, covering the surface of silage piles. It could be in feed handling, pushing the feed closer to the feed lane fence, or using some kind of trough to make sure that it’s within reach of cows within two hours. I’m getting into the weeds, but there’s a long list of best management practices that could be implemented. And some of them are quite low cost. So that would be up to the permitting structure once that accounting is done.

Miller: One of the arguments, as I’m sure you’re aware of, made by some members of the dairy industry is that it is some of the smaller operations, that nevertheless are large enough to to be governed by this potential regulation, but it’s the smaller ones which could least afford these changes that would be most affected. What’s your response to that?

Morrison: Well, my organization represents 1,600 farmers across the state, and we do have an understanding of the scale of farming in our state of Oregon. and we understand that on the smaller side, on the 700 cow versus the 30,000 cow side of this, there will be cost burdens. But that’s why these best management practices are right sized for the amount of emissions that your farm is putting out. We’re not pushing a one size fits all permitting structure. That will be determined by the amount of emissions that you are putting off. And the reason that we established that 700 cow limit- and to be clear, it’s only farms with 700 cows that use a liquid manure management system. I do want to take an opportunity to say that when we first filed the petition, we estimated that there were 91 facilities like that in Oregon. We were incorrect. We got better data from the Oregon Department of Agriculture. After filing this petition, there are only 37 facilities currently in the state that this petition would apply to. That’s 15% of all dairies in Oregon, but they house 56% of the dairy cows in facilities with CAFO permits for dairy in Oregon.

Miller: I want to run one more argument by you. The fear that that one of the the ultimate motives behind at least some of the groups who are pushing for this petition is to shut down animal agriculture. How do you respond to that accusation?

Morrison: Well, my organization, Friends of Family Farmers couldn’t be farther from that desire to shut down animal agriculture. We participate in this process and in this coalition at the behest of our farmers. We run a program called the Oregon Pasture Network, whose expressed mission is to promote and expand pasture based animal agriculture in Oregon. We’re on the steering committee of the Stand Up To Factory Farms coalition who put this out, and are constantly being consulted about how this would impact Oregon’s smallest farmers and the folks feeding their local communities. And I understand the fear. But it’s unfounded in this case. We would never stand behind something that would endanger the ability for our farmers to do the good work that they’re doing

Miller: For another perspective on this issue, we are joined right now by Tami Kerr. She is the executive director of the Oregon Dairy Farmers Association. Tami Kerr, welcome.


Tami Kerr: Good afternoon, thank you.

Miller: Good afternoon. Why is your association against this proposed regulation?

Kerr: Well, I guess to start, dairy farmers in Oregon have been very engaged and continually making investments in their farm. Animal welfare, animal care is every dairy farmer’s number one priority. And like all Oregonians, we want clean air , we want clean water, we want locally produced, locally sourced food, and we want our animals to be very well cared for. Our family farms across the state have extremely high standards, and we also have an awful lot of regulations. And any time a regulation is introduced, they often say that we only want to enforce this on the largest of farms. And there are very few examples where that has held. Normally, anytime a regulation is introduced, it always trickles down to all farms. And it’s always the smallest farms that don’t have the infrastructure, and can’t make the investment, and unfortunately go out of business. And that’s the case on this. And honestly, I don’t believe that we have an air quality [problem] in Oregon. All of the surveys and studies that I’ve looked at from EPA and other sources show that Oregon has very pristine air quality. The only parts of the state that actually have a problem are some of those with wood burning in the wintertime, and that’s Eugene, Oakridge, and Klamath Falls. But across the state, at least currently, we do have very good air quality. I always look to see what problem are we trying to solve and how are we going to get there? What’s it going to cost? And will we be able to move the needle?

Miller: Well, let’s look at one of the problems that we “are trying to solve,” which is reducing greenhouse gas emissions because of the climate crisis. According to the EPA, pound for pound, methane has 25 times the impact of carbon dioxide over the first 100 years that each of those two gasses are put into the atmosphere, and more than a quarter of the methane produced in the US right now comes from livestock. Given the climate crisis, how do you justify not regulating methane emissions?

Kerr: Well, I’d like to share some information with you on a little more historic timeline. The dairy industry has really been invested in sustainable agricultural practices before emissions were even public concern. Going back 50-60 years, producing a gallon of milk, we use 90% less land, 65% less water, and we have a 63% smaller carbon footprint than we did back in the 1940s. But on a more current timeline from 2007 to 2017, our numbers have shrunk again. We use 30% less water, 21% less land, and we have a 19% smaller carbon footprint than we did in 2007.

Miller: That’s per cow? Or you’re saying overall?

Kerr: That’s overall, yes.

Miller: Because one thing I’ve seen is that dairy cows in the state tripled in Oregon between 1997 and 2012. You’re saying despite that, there’s been a reduction in methane emissions in Oregon?

Kerr: I’m saying there’s been a reduction in methane emissions across the United States. And since about 2000, the cow numbers in Oregon have been fairly constant over the last 20 years. And we have had a decrease in our farm numbers, unfortunately. With more regulations, there’s an awful lot of additional expenses just being a business owner. And we’re struggling. We have a global economy, we have a lot of supply chain issues and a lot of our expenses on our farms have gone up substantially. Our feed costs for both our convention and organic producers have doubled and tripled in this last year. And so it’s been really challenging for our dairy farmers to stay in business. And when those farms go out of business, often neighboring farms will purchase them. If they have family members coming back, they need to grow to support additional family members to be able to make their farm have a positive cash flow. And so our farmers the last couple of years really have had to grow an awful lot more of their own feeds, growing more grass, growing more corn. And our cows demand and deserve care 24 7, 365 days a year. And so it’s really important that we can provide the care that they need and that they deserve.

Miller: How common is it for dairy owners to voluntarily do the kinds of things that Alice Morrison said she would want to see, whether it would be keeping manure in a dry form, or covering a manure lagoon or treating vented air? These are all among the potential solutions that the state would seek. How much is that actually happening right now, voluntarily?

Kerr: Some of that is already happening voluntarily. A lot of those things are very expensive as well. We are working with NRCS, we are working with other organizations, and also doing more research and and wanting to provide opportunities for our producers to be able to make those investments. And so we are, you know, manure separators, there’s a lot of technology that is happening on farm to reduce our greenhouse gas footprint. We have an improved understanding of our feed management that has reduced emissions. We do have some methane digesters that have been installed in the state that also reduces odor and it’s also had a significant reduction in our greenhouse gasses. And in the state of California over the last few years they’ve made significant investments in their dairy farms. And my understanding is that about 2% of the funds that have been invested has resulted in a 29% decrease in greenhouse gasses. They’ve built a lot of digesters in the state of California and  it’s had a huge impact for their state in a positive way.

Miller: You mentioned California. Idaho, as well, regulates emissions- ammonia admissions, at least, from dairy farms. If these two states are already regulating air quality from dairy farms, does it give you some vision of a path forward for how Oregon could do it as well?

Kerr: Oregon already has a lot of regulations on our dairy farms

Miller: In terms of water and other things, but we’re focusing specifically on air quality here.

Kerr: Right.

Miller: I’m saying, does either the California or the Idaho model give you any sense for a regulatory regime that you could, if not support at least not oppose?

Kerr: I guess I would need more specific data on the air quality, on the problem we’re trying to solve and how it would be implemented and then also the cost and who oversees it. If we’re making investments, I want to make sure that we will have that our producers can adopt practices honestly, they’re voluntarily adopting a lot of best management practices, you know, as they can afford to make investments on their farm. They are continually doing so and I would much rather see a carrot instead of a stick. But again, the results of more regulations honestly would be a larger state agencies, fewer farms and I really doubt that it would improve the air quality in our state. And when these farms have expanded, you know, over the last 20 years, again, regulations are expensive and it takes several family members to make a farm successful. And these are most definitely family farms and They don’t just grow automatically. They have to apply for their CAFO permit for expansion. There’s a lot of oversight and regulations on their nutrients,  making sure that they have enough land and that things are being applied correctly or would be, there’s a public process. There’s been a lot of oversight and public engagement on these farms that have grown over the last 20 years.

Miller: Tammy Kerr, thanks for your time today, I appreciate it.

Kerr: Thank you.

Miller: Tammy Kerr is the executive director of the Oregon Dairy Farmers Association

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