dairy cafos in california’s san joaquin valley · dairy cafos in california’s san joaquin...

Dairy CAFOs in California’s

San Joaquin Valley Local Benefits and Costs

May 2007

Chelsea N. MacMullan

Submitted to the Humane Society of the United States

The author conducted this study as part of the professional education program at the Goldman

School of Public Policy, University of California at Berkeley. This paper is submitted in partial

fulfillment of the course requirements for the Master of Public Policy degree. The judgments and

conclusions are solely those of the author, and are not necessarily endorsed by the Goldman School

of Public Policy, by the University of California, by the Humane Society of the United States, or by

any other agency.

California Dairy CAFOs

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Contents I. Executive Summary .................................................................................................................................. 5

II. Background: The Dairy Industry ........................................................................................................ 7

A. Statewide Economic Benefits of the Dairy Industry ....................................................................... 7

B. Structural Change: Technology, Systems Transformation, and Specialization ............................ 8

C. Consequence of Structural Change: Nutrient Concentration ...................................................... 10

1. Excess Nutrients and Water Quality ........................................................................................... 11

2. Excess Nutrients and Air Quality ................................................................................................ 11

III. Unpacking the Federal and State Policy Regimes .......................................................................... 12

A. Surface and Groundwater Protection Policies ............................................................................... 12

1. U.S. Environmental Protection Agency: Clean Water Act ....................................................... 12

1. NPDES Permits .............................................................................................................................. 13

2. Waste Discharge Requirement Permits ....................................................................................... 14

B. Voluntary Regulatory Water Quality Improvement Programs .................................................... 15

1. Nonpoint Source Management Program .................................................................................... 15

2. California Dairy Quality Assurance Program ............................................................................. 15

C. Air Protection Policies ....................................................................................................................... 16

1. Senate Bill 700 ................................................................................................................................. 16

2. San Joaquin Valley Unified Air Pollution Control District (SJVACPD) Regulations: Rules

4550 and 4570.......................................................................................................................................... 17

IV. Community-Level Costs and Benefits of Dairy CAFOs .............................................................. 17

A. Perspective ........................................................................................................................................... 18

B. Community Benefits of Medium to Large Dairy CAFOs ........................................................ 18

1. Employment Opportunities .......................................................................................................... 18

C. Community Costs of Medium to Large Dairy CAFOs............................................................. 18

1. Environmental Injustice ................................................................................................................ 19

a. CAFO Community Demographics: GIS Analysis ..................................................................... 21

i. Data .................................................................................................................................................. 21

ii. Methodology ................................................................................................................................... 21

iii. Results .............................................................................................................................................. 21

iv. Discussion ........................................................................................................................................ 25

2. Production Externalities Undermine Quality of Life in Local Communities ........................ 25


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a. Economic Costs .............................................................................................................................. 26

i. Economic Development ............................................................................................................... 26

ii. Property Values ............................................................................................................................... 27

b. Public Health Costs ........................................................................................................................ 28

i. Respiratory Health .......................................................................................................................... 28

i. Occupational Risks ......................................................................................................................... 29

ii. Antibiotic Resistance ...................................................................................................................... 29

iii. Water Source Contamination ........................................................................................................ 30

iv. Mental Health .................................................................................................................................. 30

c. Quality of Life Costs ...................................................................................................................... 30

i. Outdoor Activity............................................................................................................................. 31

ii. Odor ................................................................................................................................................. 31

iii. Pests .................................................................................................................................................. 31

iv. Community Development ............................................................................................................. 31

D. Other Costs ..................................................................................................................................... 32

1. Environmental Degradation ......................................................................................................... 32

2. Animal Welfare ............................................................................................................................... 32

3. National and Global Economic Impacts .................................................................................... 32

E. Discussion ............................................................................................................................................ 33

F. Criteria for Policies Addressing Local Externalities ...................................................................... 33

1. Increase Local Economic Benefit ................................................................................................ 33

2. Improve Community Health ........................................................................................................ 33

3. Increase Local Quality of Life ...................................................................................................... 34

4. Increase Equity ............................................................................................................................... 34

V. Recommendations .............................................................................................................................. 34

A. San Joaquin Valley Policy Recommendations ............................................................................ 34

B. California Policy Recommendations ............................................................................................ 36

C. Federal Policy Recommendations ................................................................................................ 38

VI. Recommendations for Further Research ........................................................................................ 38

List of Acronyms ............................................................................................................................................. 40

Works Cited ..................................................................................................................................................... 41


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Appendix A: Statistical Analysis and Regression Results .......................................................................... 45

Appendix B: Additional Maps ....................................................................................................................... 48

List of Tables Table 1: Income and Poverty by County ..................................................................................................... 19

Table 2: County Education Attainment and Language Spoken ............................................................... 20

List of Figures Figure 1: Dairy Distribution in the San Joaquin Valley ............................................................................... 9

Figure 2: CAFO Nitrogen Cycle ................................................................................................................... 11

Figure 3: State and Federal CAFO Regulatory Regime ............................................................................. 13

Figure 4: Population Density and CAFO Distribution ............................................................................. 22

Figure 5: Percent Non-White Population and CAFO Distribution ........................................................ 23

Figure 6: Percent Households in Poverty and CAFO Distribution ........................................................ 24

Figure 7: Payroll v. Reactive Organic Gas and Nitrogen Oxide Emissions ........................................... 26

Figure 9: Northern SJV Population Density ............................................................................................... 48

Figure 10: Southern SJV Population Density .............................................................................................. 49

Figure 11: Northern SJV Non-White Population ...................................................................................... 50

Figure 12: Southern SJV Non-White Population ....................................................................................... 51

Figure 13: Northern SJV Poverty Rate ........................................................................................................ 52

Figure 14: Southern SJV Poverty Rate ......................................................................................................... 53


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I. Executive Summary

Since 1993, the State of California has led the United States in milk production. Sale of milk from

California comprises about 4.6 billion of California’s 30 billion dollars in agricultural sales, and the

total economic benefits of the dairy industry to the state of California were estimated to be more than

forty billion dollars in 2004. The San Joaquin Valley, located at the southern end of California’s great

Central Valley, is the leading dairy production region in California, and is home to almost 73% of

California cows.

Over the past fifty years, technological innovations, changes in the production system, and

specialization contributed to a total restructuring of the US dairy industry. As dairy production

industrialized, the number of farms decreased while herd sized increased. Production specialized,

and livestock waste began to be treated as waste instead of valuable fertilizer for crops.

The concentration of production created major waste management concerns for dairies producing

waste in excess of soil absorption capacities. Nutrients and inorganic materials concentrated in dairy

waste compromise surface water, ground water, and air quality.

Concerns about livestock waste management generated a complicated policy regime at the local,

state, and federal levels. However, major production externalities are still imposed upon the

communities in which Concentrated Animal Feeding Operations (CAFOs) are located, due in large

part to lack of resources, information, enforcement capability and political will on the part of local

and regional regulatory agencies.

Though the dairy industry is economically beneficial to the state economy, a local perspective of

costs and benefits reveals that CAFOs do more harm than good in their local communities. CAFO

communities in the San Joaquin Valley are disproportionately non-white and poor relative to the

state of California, raising concerns about environmental justice. Dairy production externalities

adversely affect local economies, public health, and quality of life. The following policy

recommendations, specific to local, state, and federal policies, are aimed at increasing local economic

benefit, improving community health, increasing local quality of life, and increasing equity.

San Joaquin Valley Policy Recommendations

• In order to enforce federal and state standards (and protect the health and quality of life of SJV

citizens), the Central Valley Regional Water Quality Control Board (CVRWQCB) and the San

Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) should develop and

implement a strategy to collect and archive all relevant data about existing SJV dairy CAFOs and

associated manure storage structures, application fields, and production practices.

• In order to address resource and staff shortages, as well as enforce existing regulations,

CVRWQCB, SJVUAPCD, and local zoning/development boards should actively partner with

one another and with industry and related support organizations (such as CDQAP) to enforce

policies.


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• In order to stop additional growth of the dairy industry in a region already past its pollution

carrying capacity, institute a regional moratorium on new dairy CAFOs.

California Policy Recommendations

• To promote voluntary compliance with California water and air pollution regulations, set

achievable, understandable, and steady-state goals to reduce risk.

• To promote innovation, provide regulatory “safe harbor” for dairies that implement approved

technologies.

• To speed up research and development for dairy technology, fund research for new pollution

mitigation and monitoring technologies.

Federal Policy Recommendations

• In order to enforce the expanded federal CAFO regulations, develop and implement a strategy

for granting permits to CAFOs and enforcing discharge requirements. Should additional

resources be necessary to effectively enforce CAFO regulations, state regulatory agencies (such

as the CVRWQCB) should have access to such resources, contingent upon performance.


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II. Background: The Dairy Industry

Since 1993, California has led the United States in total dairy production.1 Once considered a non-

traditional dairy producing region (the Northeast is thought of as the traditional dairy producing

region in the US), California overtook Wisconsin in milk production thanks in large part to

abundant resources, most importantly land. The top-five milk producing counties in the State are in

the San Joaquin Valley, located at the southern end of California’s Central Valley. Tulare (26.5%),

Merced (14%), Stanislaus (10%), Kings (9%) and Kern (9%) counties together accounted for 65.8%

of total California milk production in 2006.2

The San Joaquin Valley is home to almost 73% of California’s cows.3 With 5.7 million acres of

available farmland, the San Joaquin Valley is recognized as one of the post productive agricultural

bioregions in the world.4 The Valley is also one of the most economically important regions in the

State of California.

A. Statewide Economic Benefits of the Dairy Industry

Sale of milk from California comprises about 4.6 billion of California’s 30 billion dollars in

agricultural sales.5 The economic benefit of the dairy industry in California was estimated to be as

high as 47.4 billion dollars in 2004, and the industry creates over 434,000 full time jobs in

California.6 Though this figure may be overestimated (the research was commissioned by the

California Milk Advisory Board), the California dairy industry is a major contributor to the economic

well-being of the state. Analysts project that milk production will increase 27% by 2015, and cheese

production will increase by 42%.7

The California Milk Advisory Board’s (CMAB) “It’s the Cheese” campaign and “Real California

Cheese” certification and branding program, launched more than ten years ago in the face of an on-

farm milk surplus, was recently adopted by the Columbia Business School as a case study for

effective industry promotion strategy.8 “As a result of the comprehensive programs put in place by

the CMAB in the 10 years since the initiative began, California has quickly developed a worldwide

1 California Dairy Research Foundation. California Dairy Facts. http://www.cdrf.org/content.asp?contentID=55. Accessed April 5, 2007. 2 California Department of Food and Agriculture. California Agricultural Resource Directory, 2006. January 2007. pp. 98-99. 3 Committee of Experts on Dairy Manure Management. Managing Dairy Manure in the Central Valley of California. Revised June 2005. University of California Division of Agriculture and Natural Resources. pp. 6. 4 Teitz, Michael, Charles Dietzel, and William Fulton. Urban Development Futures in the San Joaquin Valley. 2005. Public Policy Institute of California. pp. 27. 5 Committee of Experts. June 2005. pp. 6. 6 Dryer, Jerry. The Economic Impact of the California Dairy Business. September 2005. California Milk Advisory Board. pp. 2. (The author uses the macroeconomic principle of multipliers to estimate the total impact of each additional dollar of milk produced in California upon the economy, household earnings and employment). 7 Dryer. 2005. pp. 3. 8 California Milk Advisory Board. How California Created the Dairy Industry of the Future. 2005.


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reputation as a respected producer of many specialty, artisan and farmstead cheese types.”9

California ‘cheese tours,’ akin to traditional wine tasting tours, are providing a boon to the tourism

industry.

B. Structural Change: Technology, Systems Transformation, and Specialization

Over the past fifty years, technological innovations, changes in the production system, and

specialization contributed to a total restructuring of the US dairy industry.10 Technologies such as

mechanical milking machines, waste handling systems, and pharmaceuticals transformed the industry

from labor to capital intensive and increased efficiency.

Along with technological innovations came important changes to dairy production processes. The

electrification of rural areas (allowing for refrigeration and sanitary mass storage vats) and redesigned

milking parlors and free-stall or loafing corrals added to efficiency gains. One of the most important

changes to the milk production system was a shift from pasture-based feeding to confinement

feeding systems using imported feed. Instead of grazing cows on open pasture, dairy cows are now

most commonly fed in structures known as “Animal Feeding Operations (AFOs),” or “Confined

Animal Feeding Operations (CAFOs),” depending on the size of the herd. Corn and grain based

rations formulated precisely to the nutritional and milk production needs of cows both reduced

labor needs for feeding and increased milk production per cow by optimizing nutrient intake.11

In addition to technological advances and production structure changes, farm-level specialization is

now common in the dairy business. The total number of dairy farms decreased, geographic

distribution decreased, and average herd number increased dramatically. As the structure of the retail

food market changed and demand for milk increased, some diversified farms with milk cows as a

secondary activity had incentive to specialize in milk production to exploit economies of scale.

By increasing productivity, producers decreased cost per unit of production. In a highly competitive

commodity market with little product differentiation, low production costs and efficiency became

the most important considerations in production. According to the US Census of Agriculture, in

1940 over 76% of farms surveyed had milk cows. By 1997, that number dropped to just 6.1%. In

this same period of time, total milk production increased three-fold.12

Though milk production industrialized like many other agricultural production practices, dairy

production is unique in that most farms are still owned by families or family partnerships.

Researchers believe that availability of resources (such as land) was an important driving force in the

9 Greenwald, Michelle. Real California Cheese: It’s the Cheese. Columbia Business School. 2005. pp. 11. 10 Blayney, Don P. The Changing Landscape of U.S. Milk Production. United States Department of Agriculture Statistical Bulletin 978. June 2002. pp. v. 11 Robinson, Peter H. Interview. Cooperative Extension Specialist, Department of Animal Science, University of California, Davis, via telephone, February 27, 2007. 12 Blayney. 2002. pp. 2-6.


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Figure 1: Dairy Distribution in the San Joaquin Valley13

13 Data Source: Central Valley Regional Water Quality Control Board, Report of Waste Discharge Applications.


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growth of California dairy. Climate, family ties, and social networks are also believed to be an

important force in the geographic consolidation of California’s dairies.14

In the year 2000, the USDA Pacific production region (California, Oregon, and Washington)

produced a full 23.7% of all milk in the US, while the “traditional” milk producing Northeastern

Region produced 17.6% of milk. However, the Pacific region reported just 3,510 specialized dairy

farms, in contrast to the 23,789 specialized dairies in the Northeast.15 Dairies in the Pacific region,

lesser in number but more productive, are home to increasingly larger herds on average (see Figure 1

for a map of dairies by herd size in the San Joaquin Valley).

C. Consequence of Structural Change: Nutrient Concentration

Though the dairy industry contributes significantly to the statewide economy of California, the

structural changes described above impose negative consequences upon communities in which dairy

CAFOs reside. The specialization of production largely separates crop production from dairy

production, and the concentration of farms and increase in herd size creates a major waste

management problem. Livestock and poultry operations across the United States create over 350

million tons of manure per year.16

Manure, urine, and bedding material comprise the waste that threatens air and water quality. Used as

fertilizer, manure can provide important nutrients for crop and pasture growth. While manure was

highly valued for its nutrient content prior to the advent of synthetic fertilizer, it is now managed

and treated by most operations as waste.17 Over-application of manure to the land can impair water

and air quality. Two nutrients of major concern to air and water quality are nitrogen and

phosphorous, both of which are found in cow manure.18

Pollution from dairy waste enters the environment through three primary channels:

• Runoff of nutrients, pathogens, and organic matter to surface water;

• Leaching of nutrients and pathogens to groundwater;

• Volatilization of gases, odors, and fine particulate matter to the atmosphere.19

Groundwater pollution is an important concern in California, where many communities depend on

well-water as their primary source of drinking water. Pollutants are emitted at every stage of the

production process, including:

14 Blayney. 2002. pp. 2. 15 Blayney. 2002. pp. 17. 16 Ribaudo, Marc, Jonathon Kaplan , Lee Christensen, Noel Gollehon, Robert Johansson, Vince Breneman, Marcel Aillery, Jean Agapoff, and Mark Peters. Manure Management for Air Quality: Costs to Animal Feeding Operations of Applying Manure Nutrients to Land. June 2003. USDA Economic Research Report 824. pp. iii 17 Ribaudo, et al. 2003. pp.1. 18 Ribaudo, et al. 2003. pp.2. 19 Aillery, Marcel, Noel Gollehon, Robert Johansson , Jonathon Kaplan, Nigel Key, and Marc Ribaudo. Managing Manure to Improve Air and Water Quality. September 2005. USDA Economic Research Report 9. pp. 3

• Structures where cows are confined;

• Structures where manure is stored, such as tanks, lagoons, and ponds;

• Land to which manure is applied.

1. Excess Nutrients and Water Quality

Nitrate, salts, microbes, antibiotic metabolites, and organic compounds are present in dairy waste

and threaten ground and surface water quality.

manure or wastewater is applied above agronomic rates, nitrates and nitrites may leach beyond the

root zone (contaminating ground water) and surface runoff of solution or sediment may

contaminate surface water. Excess nutrients in surface water may cause eutrophication of the water

(algae blooms), impairing aquatic ecosystems.

application impairs subsequent plant growth and increases the salinity of ground and surface water

for municipal and irrigation use.

2. Excess Nutrients and Air Quality

Figure 2: CAFO Nitrogen Cycle22

20 Aillery, et al. 2005. pp. 3. 21 Committee of Experts. June 2005. pp. 12.22 Data Source: Aillery, et al. 2005.

Crops used for

feed

Leaching


Structures where cows are confined;

Structures where manure is stored, such as tanks, lagoons, and ponds;

Land to which manure is applied.20

Excess Nutrients and Water Quality


and threaten ground and surface water quality.21 Though nitrogen is a powerful fertilizer, when

lied above agronomic rates, nitrates and nitrites may leach beyond the


Excess nutrients in surface water may cause eutrophication of the water

(algae blooms), impairing aquatic ecosystems. Excess salt loads from manure and wastewater


Excess Nutrients and Air Quality

Committee of Experts. June 2005. pp. 12.

Loafing house

ventilation

Manure

storage

structure

Soil

Application

Crops used for

Runoff

Nitrogen gases

Nitrogen gases


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Though nitrogen is a powerful fertilizer, when

lied above agronomic rates, nitrates and nitrites may leach beyond the


Excess nutrients in surface water may cause eutrophication of the water

Excess salt loads from manure and wastewater


Nitrogen gases


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The San Joaquin Valley Air Basin (SJVAB) is a federal non-attainment area for United States

Environmental Protection Agency (U.S. EPA) ozone and particulate matter (PM10) standards.

Volatile organic compounds (VOCs) and nitrogen oxides (NOx), both precursors to ozone, are

emitted from dairies, though the emissions rates have not been studied conclusively. The natural

digestive processes in dairy cows generate methane and other VOCs (volatile fatty acids, ketones,

aldehydes, alcohols).23 In addition, methane and VOCs are emitted from manure storage and holding

structures as waste decomposes.

Atmospheric losses of nitrogen begin as soon as urine and feces mix upon excretion, and continue

throughout the handling and storage process (as depicted in Figure 2).24 Ammonia and other

nitrogen gases volatilize from free-stall or loafing houses, holding structures, soil surface, and plant

surface. Ammonia is a major cause of the odors associated with CAFOs, and it can react with NOx

to form ammonium nitrate, which is classified by the U.S. EPA as fine particulate matter.

Environmental concerns about livestock waste and odor increased in recent years. Several high

profile waste spills, primarily in the Southeast, led to lawsuits.

III. Unpacking the Federal and State Policy Regimes

The CAFO policy regime is comprised of overlapping state and federal regulations, standards, and

permitting processes. A number of different local, state, and federal agencies administer the policies

(for a schematic view of the policy regime, please see Figure 3).

A. Surface and Groundwater Protection Policies

Runoff to surface water is regulated at the federal level by the United States Environmental

Protection Agency. Groundwater protection is of particular concern in the State of California, where

many communities rely on well-water. Groundwater regulation is primarily legislated at the state

level.

1. U.S. Environmental Protection Agency: Clean Water Act

The U.S. EPA regulates livestock waste from certain types of Animal Feeding Operations through

the Federal Clean Water Act (CWA).25 The CWA primarily concerns surface water contamination

from point sources26 of pollution. The national CAFO rule was expanded in 2003 and again in 2005

23Committee of Experts. June 2005. pp 12. 24 Committee of Experts. June 2005. pp. 28, 40. 25 Environmental Protection Agency. NPDES Permit Regulation and Effluent Limitation Guidelines and Standards for

Concentrated Animal Feeding Operations; Final Rule.40 CFR Parts 9, 122, 123, and 412. 26 CAFOs are defined by the Clean Water Act as point sources for the purposes of the National Pollutant Discharge Elimination System (NPDES) program. The rule also applies to States and Tribes with authorized NPDES Programs.


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as part of a legal challenge to existing standards.27 As a result of the new rules, an estimated 15,500

AFOs are subject to federal CAFO regulations.

Figure 3: State and Federal CAFO Regulatory Regime

U.S. EPA standards define a medium dairy CAFO as an operation with 200 or more dairy cows that

confines animals for forty-five or more days in a twelve-month period and has no grass or other

vegetation in the confinement area during the normal growing season.28 A large CAFO has 600 or

more dairy cows and meets the same criteria. Operations defined as CAFOs must apply for a

National Pollutant Discharge Elimination System (NPDES) permit through the U.S. EPA, or the

state permitting authority, if that state has been authorized to assign permits. The State of California

issues NPDES permits through its regional water boards.

1. NPDES Permits

27 Waterkeeper Alliance et al. v. EPA. 399 F.3d 486. This 2005 ruling clarifies the term “agricultural storm water” and requires a publicly available nutrient management plan. 28 NPDES Permitting Guidelines. 2003. pp. 7176.


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The Central Valley Regional Water Control Board (CVRWQCB) oversees the NPDES permitting

process for the San Joaquin Valley under U.S. EPA authorization. NPDES permits, pursuant to the

U.S. EPA’s CAFO rule, specify the terms under which a facility may discharge to surface waters of

the United States. Part of the 2003 amendments to the CWA require CAFO operators to follow an

approved Nutrient Management Plan (NMP) when applying manure to crop land. NPDES permits

cover facilities and associated cropland. However, if manure is applied in accordance with an

approved NMP, storm water runoff from crop land is not regulated by the permit. As a result, the

formulation and approval of NMPs is increasingly important to the protection of surface waters, as

CAFOs that discharge during storm events are free of responsibility for the waste if they can prove

compliance with an approved NMP.

2. Waste Discharge Requirement Permits

NPDES permits in California are assigned in conjunction with California Water Code (Section

13260) required Reports of Waste Discharges (ROWD). ROWDs are applications for Waste

Discharge Requirement (WDR) permits required by any facility that discharges or proposes to

discharge to land or groundwater from any source, or in a diffuse manner.29

Dischargers that require WDR permits must provide general information to CVRWQCB, including,

but not limited to:

• Average daily volume of facility wastewater and volume or weight of manure;

• Total animal population at the facility and types of animals;

• Animal capacity of the facility;

• Location and size of use or disposal fields and retention ponds, including animal capacity.30

In addition, any material changes to the operation must be reported to CVRWQCB, animals must

be prevented from entering any surface water within the CAFO, and local administrators can

monitor changes to dairies by requiring construction permits. Storm water runoff from associated

crop land is regulated under WDR permits, which do not allow any discharge that could adversely

affect water quality.31 Additional standards and regulations for dairy permits include:

• State appraisal of waste structure sites before development;

• Compliance with specific design standards;

• Lagoons lined with soil comprised of ≥ 10 % clay, and ≤ 10% gravel;

29 Office of Wastewater Management, U.S. Environmental Protection Agency. State Compendium, Programs and Regulatory Activities Related to Animal Feeding Operations. pp. 42. 30 Office of Wastewater Management. May 2002. pp. 42. 31 Office of Wastewater Management. May 2002. pp. 44.


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• Existing waste storage structures must contain wastewater and precipitation up to and

including a 25-year, 24-hour storm.32 New structures must contain waste water and

precipitation from a 100-year storm;

• Land application restricted to “reasonable rates” that do not cause surface runoff and do

minimize leaching into groundwater.33

CVRWQCB’s newest WDR General Order for livestock has not yet been finalized, but a tentative

plan was released on March 27, 2007. Most dairies in the San Joaquin Valley must apply for a WDR

permit, and facilities meeting the federal definition of medium and large CAFOs must jointly apply

for an NPDES permit in order to legally operate. Legal discharge levels for NPDES and WDR

permits have traditionally been set at zero for agricultural operations.

B. Voluntary Regulatory Water Quality Improvement Programs

1. Nonpoint Source Management Program

NPDES and WDR permitting programs reflect that most pollution from dairy waste is regulated as

a point source. However, the State Water Resources Control Board (SWRCB), California Coastal

Commission (CCC), and Regional Water Quality Control Boards (RWQCB) developed a long term

plan for managing non-point source (NPS) agricultural pollution to protect ground and surface

water in compliance with CWA Section 319.34

Section 319 provides grant funding for NPS improvement programs and AFO assessment,

contingent upon a state plan for managing NPS pollution. California’s management plan includes

education and outreach efforts, as well as commitments to inspection and complaint-response. In

addition, the State is in the process of developing Total Maximum Daily Load (TMDL) standards

with which to enforce NPS standards.

2. California Dairy Quality Assurance Program

The California Dairy Quality Assurance Program (CDQAP) is a partnership between California state

and local agencies, the academic community, and the dairy industry. CDQAP’s mission is to help all

dairies achieve compliance with federal, state, and local regulations.

CDQAP provides free services to California dairies including:

• Environmental stewardship, food safety, and animal health and welfare short-courses;

• Environmental stewardship farm management plans;

• Onsite evaluations by a third party;

32 Refers to the most intense 24-hour storm in the past 25 years. 33 Office of Wastewater Management. May 2002. pp. 44. 34 California State Water Resources Control Board. Non Point Source Management Plan, Section II Five Year

Implementation Plan. 2003. pp. 2.


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• Recertification;

• Quality control of the evaluation process.

Dairies can be certified in environmental stewardship by CDQAP, but the certification has no

regulatory weight other than the guarantee that a facility is in compliance with all legal regulations,

should it be inspected. In other words, certification offers no official status, and therefore no

guarantee against inspection and regulation.

C. Air Protection Policies

CWA amendments and NMP requirements were established in the interest of protecting surface and

ground water. However, a logical response by farmers constrained by an NMP is to reduce the

nutrient content of manure by allowing gases to volatilize to the atmosphere from uncovered

lagoons or applying manure to the land without incorporating it into the soil. Such practices

compromise air quality, specifically in the form of nitrogen-derived ammonia emissions, volatile

organic compounds (VOCs) and Particulate Matter.35 Each of the eight counties in the San Joaquin

Valley is classified as a “severe” or “serious” non-attainment area for ozone and PM10.36

California recently ramped up its efforts to create an air pollution permitting system for CAFOs,

especially in federal non-attainment areas for U.S. EPA ambient air quality standards. Federal laws

require permits for agricultural sources of air pollution. Until 2003, California granted air permit

exemptions to agricultural sources of pollution, and faced substantial federal fines if it did not

remove the exemption. In response, the state legislature passed Senate Bill 700 in 2003.

1. Senate Bill 700

On September 22, 2003 California Governor Gray Davis signed into law Senate Bill (SB) 700, a bill

amending air pollution control requirements to include restrictions for agricultural sources of air

pollution.37 Prior to SB 700, agricultural operations were exempted from air pollution permits. SB

700 includes several important guidelines:

1. Defines “agricultural source” under state law;

2. Removes the restriction from state law that prevented regional air districts from requiring

permits for agricultural operations;

3. Creates specific permit and exemption requirements for agricultural sources;

4. Requires emission regulations for areas not meeting the National Ambient Air Quality

standards for PM10;

35 Aillery et al. September 2005. pp. iii. 36 California Air Pollution Control Officers Association (CAPCOA), White Paper on SB 700. April 2004. pp. 23. 37 CAPCOA, April 2004. pp. 3.


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5. Requires permits and emissions mitigation for AFOs defined as “large” by the California Air

Resources Board research on contribution to total emissions.38

The California Air Resources Board (CARB) was charged with the task of defining large confined

animal facilities for the purpose of regulation.

CARB released the following regulatory definition of a large CAFO:

a) In any area designated as a federal ozone nonattainment area as of January 1, 2004, any

confined animal facility that maintains on any one day: 1,000 or more milk-producing dairy

cows;

b) In any area other than an area described in subsection (a) above, any confined animal facility

that maintains on any one day: 2,000 or more milk-producing dairy cows.39

2. San Joaquin Valley Unified Air Pollution Control District (SJVACPD) Regulations: Rules

4550 and 4570

Granted the ability to regulate agricultural sources of air pollution by SB 700, SJVAPCD released its

implementation plan for SB 700 on May 20, 2004. SJVACPD passed Rules 4550 and 4570, requiring

the adoption of Conservation Management Practices (CMPs) to reduce fugitive dust emissions.

Dairies with more than 500 mature dairy cows or 100 contiguous acres are required to adopt CMPs.

Rule 4570 is aimed at reducing the emissions of VOCs from dairies. Adopted in June 2006, the rule

requires any dairy with more than 100 cows to apply for a permit and adopt an approved emissions

mitigation plan.40 In addition, SJVACPD is currently developing a set of required “Best Available

Control Technologies” (BACTs) for use in its dairy permitting process.

Large confined animal operation permit applications were due on January 1, 2007. Permits are to be

issued within six months. Once complete, the board will require dairies meeting the definition of a

large CAFO to adopt an appropriate BACT.41 The facility will have one year to implement the

technology.

IV. Community-Level Costs and Benefits of Dairy CAFOs

There are over 1200 dairies in the San Joaquin Valley that together house over one million dairy

cows.42 The concentration of dairies and the resulting waste management challenge have serious

consequences for the communities in which dairies locate. An examination of the benefits and costs

38 CAPCOA. April 2004. pp. 4. 39 Final Regulation Order for the Definition of Large Confined Animal Facility. California Code of Regulations. Title 17. Division 1. Chapter 1. Subchapter 2.7. 40 San Joaquin Valley Unified Air Pollution Control District. Rule 4570. Adopted June 2005. 41 Dairy Permitting Advisory Group. Recommendations to the San Joaquin Valley Air Pollution Control Officer Regarding Best Available Control Technologies for Dairies in the San Joaquin Valley. January 31, 2006. pp. 7. 42 Data Source: Central Valley Regional Water Control Board


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at the community level is essential to understanding the local social and economic effects of dairy

CAFOs.

A. Perspective

The focus of this paper is on the benefits and costs of dairy CAFOs from the local perspective.

From this perspective, the benefits and costs that accrue to the citizens of the communities in which

CAFOs locate are considered. Wider economic benefits to the California economy, as well as wider

economic and environmental costs, are not considered in detail.

B. Community Benefits of Medium to Large Dairy CAFOs

As discussed above, the highly productive California dairy industry is hugely beneficial to

California’s agricultural economy. However, very few benefits from the dairy industry accrue directly

to the citizens of the communities in which dairy CAFOs locate. There are few documented local

benefits of dairy CAFOs beyond the employment opportunities provided by medium to large

facilities.

1. Employment Opportunities

Dairies in the SJV provide employment opportunities for local residents, both direct and indirect.

Agricultural employment is the leading employment category in Fresno and Madera counties.

However, as capital intensive farms, the employment benefits may be limited. A 1998 swine-CAFO

study estimated that three to four jobs were created for each 1000 sows in the operation.43

Economists estimated that each farm job adds another job to the local community, and $1 of farm

income adds $1 of income to the local community.

However, the impact of these multipliers will depend on how laborers are hired- locally, or through

contractors (who often commute) -- and on what proportion of inputs are purchased within the

community.44 Evidence suggests that the majority of inputs, such as corn and grain-based feed,

antibiotics, and equipment, are purchased from other regions, such as the Midwestern Corn Belt and

Canada.45 Because much of the revenue from dairy production is reinvested into communities

outside of the San Joaquin Valley, the one-to-one multiplier for farm income and local income is

likely to be less in this area.

C. Community Costs of Medium to Large Dairy CAFOs

Despite the economic importance of the San Joaquin Valley, communities in the region are relatively

underprivileged relative to the rest of California. Communities with large stocks of political capital

are poor locations for CAFOs, because the externalities associated with dairy production are

43 Weida, William. Considering the Rationales for Factory Farming. March 29, 2004. Presented at: Environmental Health Impacts of CAFOs: Anticipating Hazards, Searching for Solutions. Iowa City, IA. 44 Sporleder, T. Ohio Food Income Enhancement Program. 1997. Agricultural, Environmental, and Development Economics Department. Ohio State University. 45 Interview with Deanne Meyer. April 2, 2007.


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unattractive to local groups. More affluent communities resist local establishment of CAFOs when

possible, making it more expensive for producers to establish CAFOs nearby. Therefore, CAFOs

often locate in communities with the least political influence.

1. Environmental Injustice

According to the U.S. EPA, environmental justice will be achieved when “everyone enjoys the same

degree of protection from environmental and health hazards and equal access to the decision-

making process to have a healthy environment in which to live, learn, and work.”46 Though only

about 9% of the state’s population lives in the San Joaquin Valley (SJV), the region accounts for

approximately 15% of the state’s EPA-regulated criteria pollutants.47 The pollution present in the

San Joaquin Valley is especially troubling when one considers the demographic makeup of

communities in the SJV relative to the state of California. Persons in the SJV are likely to have less

political capital and less access to restitution from costs imposed by dairy CAFOs.

Table 1: Income and Poverty by County

County Income Per Capita 1999 Percent People Below Poverty Level 1999

Fresno $15,495 22.9

Kern $15,760 20.8

Kings $15,848 19.5

Madera $14,682 21.4

Merced $14,257 21.7

San Joaquin $17,365 17.7

Stanislaus $16,913 16.0

Tulare $14,006 23.9

California $22,711 14.2

Source: Perez and Curtis, 2003 (same applies to Table 2)

The San Joaquin Valley is one of the least affluent regions in the State of California. While the

average poverty rate in California is 14.2%, the average rate in the eight counties of the San Joaquin

46 U.S. EPA. Compliance Website. April 14, 2007. http://www.epa.gov/compliance/environmentaljustice 47 Perez, Miguel, and Kathleen Curtis. Healthy People 2010: A 2003 profile of health status in the Central San Joaquin

Valley. 2003. California State University, Fresno. pp. 8.


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Valley is 20.49%.48 According to the 2000 US Census, thirteen of the nation’s 101 poorest

communities are located in the SJV. The unemployment rate in the SJV is 12.9%, compared to the

3-4% rates reported for the U.S., and the 5.2% average for the state of California.49 Average income

per capita and poverty rates for the eight counties of the SJV and the state of California are listed in

Table 1.

In addition to below average economic status, citizens of the SJV are on average less educated than

other Californians. They are also more likely to speak a language other than English in the home--

indicating below-average proficiency in language. Table 2 lists educational attainment rates and

language statistics for the eight counties of the SJV and the state of California.

Table 2: County Education Attainment and Language Spoken

County Percentage People Age 25 and up with a High School

Diploma

Percentage People Age 25 and up with a Bachelor

Degree

Language Other than English Spoken in

Home

Fresno 67.5 17.5 40.8

Kern 68.5 13.5 33.4

Kings 68.8 10.4 36.7

Madera 65.4 12.0 37.0

Merced 63.8 11.0 45.2

San Joaquin

71.2 14.5 33.7

Stanislaus 70.4 14.1 32.4

Tulare 61.7 11.5 43.8

California 76.8 26.6 24.9

The San Joaquin Valley is home to a disproportionate amount of California’s pollution, while

simultaneously suffering from higher-than-average poverty rates and lower than average per-capita

income, education, and English proficiency. These statistics reflect that those affected by

externalities from dairy production in the San Joaquin Valley are more often the politically and

socially disenfranchised. Environmental justice in the San Joaquin Valley has not been achieved.

48 Perez and Curtis. 2003. pp. 2. 49 Perez and Curtis. 2003. pp. 11.


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a. CAFO Community Demographics: GIS Analysis

In order to examine environmental justice and equity in the San Joaquin Valley, the relationship

between CAFO location and demographic characteristics was analyzed. Geographic Information

System was used to create maps overlaying CAFOs by herd size and various demographic variables.

The analysis compares the demographic characteristics of block groups with varying numbers of

dairy cows.

i. Data

Data on dairy geographic location and herd size was provided by CVRWQCB.50 The information

was compiled from ROWD applications for WDR permits submitted by dairy operators. The

poverty, race, and population density data is from the 2000 Census, Summary File 3. Data for the

eight counties in the SJV are divided by census block group. Block groups are the smallest area for

which relevant demographic data is available.

ii. Methodology

Using Geographic Information System (GIS) software, the dairy location and herd size data was

overlaid with Census demographic data on population density, households in poverty, and non-

white population percentages. Facility and animal counts per block group were calculated using

spatial analysis tools in GIS. A multiple regression analysis was run including all block groups, and

another including only block groups with greater than zero cows (201 of the 2285 block groups in

the SJV were home to dairy cows). Number of cows per block group was the dependent variable

and population density, household poverty rate, and non-white population rates were the

explanatory variables. The regression was specified in simple multivariate regression form for both

cases, and using the natural log of cows in each block group in a Poisson regression for block

groups with >0 dairy cows.

It was also of interest to examine the influence of total number of cows, poverty, and race upon

population density. A fourth regression was specified using the natural log of population density as

the dependent variable and the variables mentioned above as explanatory variables. Because

population density influences CAFO location, and vice versa, this regression allows for an

examination of the bias this may cause in the original model specification.

iii. Results

The results of this analysis were more visually striking than statistically conclusive (see Figures 4-6).

Population density in the San Joaquin Valley is extremely sparse, with populations concentrated in

urban centers such as Fresno and Modesto. The results of the regression may be driven by the lack

of cows in the most highly populated areas. The distribution of non-white population and poverty

rate appears to follow the distribution of CAFOs, though no conclusions can be drawn directly from

50 Thanks to CVRWQCB contacts Steven Hulbert (Fresno Office) and Charlene Herbst (Sacramento Office) for providing ROWD data.


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Figure 4: Population Density and CAFO Distribution51

51 Data Sources: U.S. Census 2000 & CVRWQCB


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Figure 5: Percent Non-White Population and CAFO Distribution52

52 Data Sources: U.S. Census 2000 & CVRWQCB


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Figure 6: Percent Households in Poverty and CAFO Distribution53

53 Data Sources: U.S. Census 2000, CVRWQCB


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visual appraisal. In each model specified with total cows as the dependent variable, population

density was the only statistically significant explanatory variable (for regression outputs, please see

Appendix A). The coefficient on poverty rate approached significance in the simple multivariate

model including all block groups. In the regression on the natural log of population density, the

coefficients on both poverty rate and total number of cows were negative and statistically significant.

Magnified maps of the Northern and Southern ends of the San Joaquin Valley are included in

Appendix B.

iv. Discussion

The demographic characteristics of the San Joaquin Valley relative to the rest of the State may

explain some of the results seen in this analysis. The region is home to more poverty and minority

communities on average than the rest of the state. Therefore, comparing block groups within the

county provides a limited amount of variation within the data analyzed.

In addition, it is hard to determine the direction of the relationship between CAFO location and

population density, poverty, and minority population. Rural communities are traditionally home to

more persistent poverty than metropolitan areas. Land is cheaper and more abundant in rural,

sparsely populated areas, making these regions attractive locations for large animal feeding

operations, which require large parcels of land. While the lack of political capital (due to low socio-

economic status) among the citizens of these communities may also make the region attractive, it

would be difficult to parse out the two effects. Regressing our explanatory variables upon the natural

log of population density is suggestive of the theory that poverty, population density, and CAFO

location simultaneously influence one another.

It may be that the specific within-valley location of dairy CAFOs is less important than I assumed in

designing this analysis. When one considers the non-excludable nature of runoff and emissions from

dairy CAFOs in an arid valley setting such as the SJV, within-valley block group comparisons may

be unimportant. If everyone living in the valley is affected by production externalities from CAFOs

(in the form of contaminated ground and surface water, ambient air quality, and quality of life

effects) it may be the case that a statewide comparison is essential to an accurate spatial analysis. But

given that geographical and historical factors render most of the state inappropriate for large dairy

CAFOs, this analysis would be fraught with limitations.

Given the time and resources available, a statewide comparison was not possible. However, a

detailed analysis of the entire state, including more variables omitted from this analysis, would be

valuable to understanding the placement patterns of dairy CAFOs seen in these maps, as well the

social and economic effects of CAFOs on local communities.

2. Production Externalities Undermine Quality of Life in Local Communities

If dairy production adversely affects CAFO communities without proper compensation, the dairy

industry can be said to impose externalities upon SJV residents. CAFO policies fail to regulate these

externalities due to a lack of information and a lack of resources. If the total social cost of milk

production is not internalized by dairy producers, production will be maintained at a level above the

social optimum (where social benefit is equal to social cost). As discussed above, the burden of this

externality would fall upon a population that is already somewhat disenfranchised.

of the costs of production borne by CAFO communities indicates that dai

consider total social costs in management decisions.

a. Economic Costs

i. Economic Development

Research indicates that concentration and industrialization of agricultural production removes more

money from the community in which a farm is lo

area.54 A comparative study of Central Valley communities dominated by one industrial farm versus

communities with multiple locally owned and operated farms showed that the communities with

smaller farms had better social and civic institutions, more even distribution of wealth, and more

Figure 7: Payroll v. Reactive Organic Gas and Nitrogen Oxide Emissions

local retail purchases.56 A similar study showed that the concentration of agriculture was associated

with local and regional economic and social declines.

54 Donham, Kelley, Steven Wing, David Osterberg, Jan Flora, Carol Hodne, Kendall Thu, and Peter Thorne. Community Health and Socioeconomic Issues Surrounding Concentrated Animal Feeding Operations.Environmental Health Perspectives. 115(2). pp. 317.55 California Partnership for the San Joaquin Valley. April 15, 2007. http://www.bth.ca.gov/capartnership/pdf/AirQualityandEnvironmentalProtection.pdf

0

2

4

6

8

10

12

14

1.59

6.94

% SJV Payroll


upon a population that is already somewhat disenfranchised. An examination

of the costs of production borne by CAFO communities indicates that dairy producers fail to

consider total social costs in management decisions.


money from the community in which a farm is located than when smaller farms operate in the

A comparative study of Central Valley communities dominated by one industrial farm versus


er social and civic institutions, more even distribution of wealth, and more

: Payroll v. Reactive Organic Gas and Nitrogen Oxide Emissions55

A similar study showed that the concentration of agriculture was associated

with local and regional economic and social declines.57

Donham, Kelley, Steven Wing, David Osterberg, Jan Flora, Carol Hodne, Kendall Thu, and Peter Thorne. Community Health and Socioeconomic Issues Surrounding Concentrated Animal Feeding Operations. February 2007.

rspectives. 115(2). pp. 317. California Partnership for the San Joaquin Valley. Overview Report for the Air Quality Work Group.

http://www.bth.ca.gov/capartnership/pdf/AirQualityandEnvironmentalProtection.pdf

5.58

9.04

1.06

2.59

12.21

6.37

% SJV Payroll % SJV ROG and NOx Emissions


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An examination

ry producers fail to


cated than when smaller farms operate in the

A comparative study of Central Valley communities dominated by one industrial farm versus


er social and civic institutions, more even distribution of wealth, and more

A similar study showed that the concentration of agriculture was associated

Donham, Kelley, Steven Wing, David Osterberg, Jan Flora, Carol Hodne, Kendall Thu, and Peter Thorne. February 2007.

Overview Report for the Air Quality Work Group. Accessed http://www.bth.ca.gov/capartnership/pdf/AirQualityandEnvironmentalProtection.pdf

6.37


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Figure 7 represents the percentage of payroll contributions versus contributions to reactive organic

gas and nitrogen oxide emissions for four of the largest SJV industries. The dairy industry’s share in

emissions is almost six times greater than its share in the regional payroll and the ratio is worse even

than petroleum production and marketing- an industry traditionally thought to be one of the largest

contributors of atmospheric pollution. These figures indicate that the costs of dairy production to

environmental health may outweigh the economic benefits.

The seasonal “colonias”- essentially large labor camps housing seasonal agricultural workers, most of

who emigrate to the SJV from Mexico, pose major challenges for local social services.58 The colonias

are a by-product of increasingly industrialized agriculture that impairs the development and growth

of SJV communities. As long as agriculture dominates the economy of the SJV, low-skilled workers

will consider the region a destination for employment opportunities. This may expand the

agricultural sector, and with it the low-paid, low-skilled job sector.59 The low wages paid to migrant

workers impair significant economic growth by perpetuating widespread poverty.

As low-paid, low-skilled jobs dominate the job market in the SJV, economic development and the

introduction of higher-skilled job sectors may be prevented. A study by The Fresno Bee found that

average earnings in Fresno, Madera, and Tulare counties lagged behind the rest of the state. Farm

workers were the largest category of workers in Fresno and Madera counties. Just two of the top ten

employment categories earned on average more than $29,000 per year (grade school teachers and

nurses).60 The pollution, health risks, and odors associated with dairy CAFOs increase the

probability that the region will continue to be primarily agricultural, as large employers will not

locate in the Valley at the risk of low employee-retention rates and/or increased health care costs.

ii. Property Values

Depending on the proximity to the CAFO and type of CAFO, property values in farming

communities plummet after construction of a CAFO.61 Decreased marketability, loss of use and

enjoyment, and loss of exclusive use were shown in various case studies to decrease property values

by 10-40% of otherwise unimpaired values.62 If CAFOs lower the assessed tax base by reducing

56 Goldschmidt. Agribusiness and the rural community. 1978. As You Sow: Three Studies in the Social Consequence of Agribusiness. Allenheld, Osmun, and Co. 57 MacCannell, Dean. Industrial Agriculture and Rural Community Degradation. 1988. In: Agriculture and Community Change in the U.S.: The Congressional Research Reports. pp. 15–75. 58 Cowan, Tadlock. California’s San Joaquin Valley: A Region in Transition. 2005. CRS Report for Congress. pp. 7. 59 Cowan. 2005. pp. 9. 60 Cowan. 2005. pp. 21. 61 Kilpatrick, John. Concentrated Animal Feeding Operations and Proximate Property Values. 2001. The Appraisal Journal. LXIX(3). Palmquist, R, F. Roka, and T. Vukina. Hog operations, environmental effects, and residential property values.1997. Land Economics. 73. pp. 114-124. 62 Kilpatrick. 2001. pp. 9.


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property values, while imposing environmental externalities upon a community, the facility

simultaneously works to reduce local resources while increasing local costs. Reduced property value-

- in both absolute terms and in terms of personal enjoyment-- is perhaps the most directly

observable financial externality imposed upon neighbors of dairy CAFOs.

b. Public Health Costs

i. Respiratory Health

CAFO waste decomposition in holding structures and on the fields to which it is applied creates a

complex mixture of dust particles, bacteria, endotoxins, VOCs, and ammonia-- a highly odorous

gas.63 As a federal non-attainment region for particulate matter and ozone, residents of the San

Joaquin Valley face increased respiratory health risks. Air quality in the SJV air basin is especially

poor because of the “low pollution carrying capacity” of the area. Several factors contribute to the

low carrying capacities:

• Surrounding mountains restrict air flow in and out of the valley, impairing dispersion of

pollution;

• Surrounding mountains entrap pollution ‘drift’ from other air basins;

• Rapid daytime heating of the air and intense sunlight contribute to efficient formation of

smog and ozone;

• The valley is prone to thermal inversions, which concentrate pollution as the area of the

dispersion layer decreases.64

A multipart series in The Fresno Bee detailing air quality in the Valley stated that “the San Joaquin

Valley may be the most dangerous place in the United States to breathe.” In 1999, the SJV air basin

surpassed the South Coast air basin in eight-hour ozone violations. This is remarkable given that the

South Coast air basin is home to a population eighteen times as dense as that of the SJV. 65

Exposure to ozone, even at low rates, can decrease lung function and make at-risk groups (the

elderly and children) more susceptible to respiratory diseases.66 A recent survey by the Public Policy

Institute of California placed air pollution and the perceived associated health risks at the top of the

list of concerns for SJV residents.67

The SJV has a higher than average death rate from Chronic Obstructive Pulmonary Disease

(COPD), and some of the highest asthma rates in the nation. The regional prevalence rate for

63 Osterberg, David and David Wallinga. Addressing Externalities from Swine Production to Reduce Public Health and Environmental Impacts. October 2004. American Journal of Public Health. 94(10). pp.1705. 64 Meyer, Deanne. Cooperative Extension Specialist, Dairy Waste Management. Interview: April 2, 2007. University of California, Davis. 65 The Fresno Bee. The Last Gasp. December 15, 2002. http://www.valleyairquality.com/ Accessed April 15, 2007. 66 Perez and Curtis. 2003. pp. 17. 67 Baldassare, Mark. Special Survey of the Central Valley. June 2006. Public Policy Institute of California. pp. vi.


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asthma is 16.9%, while the statewide prevalence is only 9.6%.68 The SJV has one of the highest rates

of pollution-attributable mortality in the United States. Researchers have documented higher rates of

respiratory symptoms in communities neighboring large CAFOs, relative to comparison groups in

regions with low-density agricultural production.69

i. Occupational Risks

Exposure to CAFO gases is intensified for workers who spend hours within the confines of milking

parlors and free-stall or loafing barns. Chemical decomposition of animal waste begins from the

moment of excretion, and dairy workers (often residents of local communities) are therefore at a

higher risk of adverse health effects than citizens experiencing ‘downwind’ effects.

Analysis of toxin levels in the air in swine confinement facilities in North Carolina revealed

unhealthy levels of hydrogen sulfide, ammonia, fine particulate matter, and endotoxins.70 Respiratory

diseases associated with CAFO employment include: Sinusitis, Irritant Rhinitis, Allergic Rhinitis,

Pharyngitis, Alveolitis, Pulmonary Edema, Organic Dust Toxic Syndrome, Occupational Asthma,

Non-allergic Asthma, Reactive Airways Disease Syndrome, Allergic Asthma, Chronic Bronchitis,

and COPD.71

Given that agricultural jobs often employ undocumented, uninsured workers, the effects of CAFO-

related disease in the SJV may be intensified in terms of suffering and loss of welfare. ii. Antibiotic Resistance

Infectious livestock diseases spread rapidly in large herds of confined animals. As a preventive

measure, many operators regularly administer antibiotics in feed. Seventy percent of the antibiotics

produced in the United States are fed to animals to reduce infection and increase production,72 and it

is estimated that up to 75% of these antibiotics are excreted in manure and urine.73

The Union of Concerned Scientists estimates that 13 of the 20 million pounds of antibiotics

administered to animals each year are ‘medically important’- meaning that they are closely related to

medicines used in humans.74 The abuse of antibiotics in food production expedites the rise of

antibiotic resistant strains of bacteria, which may be transferred to humans through the food supply

and groundwater contamination. CAFOs have been referred to as “reservoirs of antibiotic

resistance.”75 The World Health Organization noted that drug-resistant strains of Salmonella,

68 Perez and Curtis. 2003. pp. 18. 69 Donham, et al. 2007. pp. 318. 70 Donham, et al. 2007. pp. 318. 71 Osterberg and Wallinga. pp. 1705. 72 Horrigan, Leo, Robert Lawrence, and Polly Walker. How Sustainable Agriculture can Address the Environmental

and Human Health Harms of Industrial Agriculture. May 2002. Environmental Health Perspectives. 110(5). pp. 451. 73 Osterberg and Wallinga. 2004. pp. 1705. 74 Osterberg and Wallinga, 2004. pp. 1705. 75 Osterberg and Wallinga. 2004. pp. 1703.


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Campylobacter, Enterococci, and E. coli have been transmitted from animals to humans, and called

for the reduced use of antibiotics in food production.

Those living near CAFOs have a higher risk of exposure to drug-resistant strains of bacteria,

through groundwater leaching, water-source contamination, and physical contact with waste.

iii. Water Source Contamination

Bacteria, microbes, and residual antibiotics are passed from dairy cows in manure. Manure stored in

holding ponds and lagoons that are improperly constructed or maintained may contaminate local

water sources through leaching or runoff. Samples from storage lagoons contained traces of

antibiotics administered in feed.76 Microbes that are toxic to humans thrive in water with high

nutrient concentration, and decompose nitrogen found in manure into nitrates77 Ingestion of nitrate

contaminated water can lead to the sometimes fatal shortage of oxygen in the blood of infants,

called Methemoglobinemia, or “blue baby syndrome.”78

In rural communities such as those found in the SJV, many rely on well water. The United States

Geological Service found nitrate concentrations that violated drinking water standards in 25% of

residential wells sampled in the SJV.79 Residents of the SJV are more likely to be exposed to

antibiotic residue, bacteria, and nitrates due to the high concentrations of dairy CAFOs in the water

basin.

iv. Mental Health

The effects of CAFOs upon mental health have not been researched extensively. However,

preliminary research, most of which concerns communities around swine CAFOs in the Midwest

and Southeast (swine CAFOs impose many of the same environmental effects as dairy CAFOs), is

suggestive.

Living in close proximity to hog CAFOs has been linked to higher rates of self-reported depression,

anxiety, and impaired mental health.80 Surveys administered during four days on which hog odors

could be smelled in the CAFO communities revealed that those experiencing odors had higher rates

of depression, tension, anger, fatigue, and confusion than the controls.81 The effects of CAFO

externalities upon mental health need to be examined more thoroughly, but preliminary evidence

suggests a possible deleterious effect.

c. Quality of Life Costs

76 Osterberg and Wallinga. 2004. pp. 1706. 77 Horrigan et al. May 2002. pp. 451. 78 Osterberg and Wallinga. 2004. pp. 1704. 79 Cowan. 2005. pp. 261. 80 Donham, et al. 2007. pp. 318. 81 Cole, Dana, Lori Todd and Steve Wing. Concentrated Swine Feeding Operations and Public Health: A review of

Occupational and Community Health Effects. 2000. Environmental Health Perspectives. 108(8). pp. 693.


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i. Outdoor Activity

The symptoms associated with asthma and other respiratory disease adversely affect quality of life,

especially among children. Poor air quality often prevents the enjoyment of outside activities and

physical exercise. The SJVAPCD adopted recommendations for “active indoor recess” in valley

schools on poor air quality days when children are advised not to play outdoors. CAFOs contribute

to this impairment of activity which no doubt impairs childhood development.

ii. Odor

Odors associated with dairy CAFOs are not only a nuisance, but also a hindrance to community and

social growth. Residents in communities near large CAFOs cannot enjoy outdoor activities on many

days due to unpleasant odor and the health risks associated with the odor. In communities where a

large part of community life is rooted in outdoor activity, this can have detrimental effects upon the

social fabric of the region.82

An essential component of being a home or property owner is the right to “exclusive use” of one’s

property. This right is pre-empted on days when air quality and odors are poor and individuals are

unable to enjoy their property to its fullest extent. This loss of the right -to -use one’s property

decreases the utility of owning property in the San Joaquin Valley.

iii. Pests

CAFOs and associated manure storage structures and spraying fields attract flies and other insects

that parasitize dairy cows. These pests are a nuisance to neighbors and represent possible disease

vectors. Because pesticides are often applied to animals in confinement to control flies and other

insects, traces of the pesticides are found in CAFO waste and may leach or runoff to local water

sources, posing additional health threats to the public and local community.83

iv. Community Development

Economic development models suggest that as the scale of farms increase and the number of farms

decrease, the community structure of rural communities change in a fundamental way. Individual

well-being becomes more vulnerable to the ups-and-downs of the global economy as local

production is geared towards producing undifferentiated commodity goods. Setback requirements

for CAFOs often hinder community development, as anyone wishing to move within limits of the

setback radius must sign away rights to exclusive use. 84

The poor air quality, odor, and health risks associated with dairy CAFOs decrease the desirability of

SJV communities. This may be one explanation for the significantly negative relationship seen

82 Thu, K. Public Health Concerns for Neighbors of Large-Scale Swine Production Operations. 2002. Journal of Agricultural Safety and Health. 8(2). pp. 175. 83 Environmental Protection Agency. NPDES Permit Regulation and Effluent Limitation Guidelines and Standards for

Concentrated Animal Feeding Operations; Final Rule.40 CFR Parts 9, 122, 123, and 412. pp. 7236. 84 Weida. 2004.


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between population density and total number of cows per block group. The benefits often

associated with rural areas-- abundant land, outdoor activity, and access to nature-- are significantly

reduced in the presence of CAFOs. Community development through outdoor activities such as

farmers markets is less frequent, if present at all.

D. Other Costs

Dairy CAFOs impose costs to society beyond the community-perspective assumed in this analysis.

As the wider benefits to California of a productive dairy industry were discussed in section II, the

wider costs of dairy production will now be considered briefly.

1. Environmental Degradation

Industrial agriculture contributes to environmental degradation at the national and global level. The

specialization of production necessitated inputs and created waste management problems that are

unsustainable. Feeding cows formulated feed trucked in to the Valley from grain-producing regions

leads to pollution that was unnecessary when cows grazed pastures fertilized by their waste.85

Pollution from dairy CAFOs in the SJV has effects beyond the confines of the region, for example,

through the contamination of the Sacramento delta water basin. On a global level, industrial

agriculture is one of the largest greenhouse gas contributors.86 In addition, the geographic

concentration of food production necessitates the use of fossil-fuels for product transport.

2. Animal Welfare

Dairy production facilities can have detrimental impacts on the welfare of heifers and cows. For

more information, please see www.FarmAnimalWelfare.org.

3. National and Global Economic Impacts

Milk and other animal products are artificially cheap in the United States. Federal and state subsidies

for agricultural production lead to overproduction. The federal government supports a long-

standing milk price support program that keeps farmers in business even when economic forces

would naturally drive them out of the market.87 The failure to internalize societal costs of production

contributes to over-production and under-pricing, as producers do not incur the total social cost of

milk production.

Over-production of milk has important national and global consequences. Cheap animal products

increase consumption (beyond the social and medical optimum), compromising cardiovascular

85 Interview with Deanne Meyer. April 2, 2007. 86 Steinfeld, Henning, Pierre Gerber, Tom Wassenaar, Vincent Castel, Mauricio Rosales, and Cees de Haan. Liverstock’s Long Shadow: Environmental Issues and Options. Food and Agriculture Agency of the United Nations. Rome, 2006. 87 Miller, James and Don Blayney. Dairy Backgrounder. July 2006. Economic Reasearch Service. United States Department of Agriculture.


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health and imposing indirect public health costs. Cheap animal products from the United States

flood the global market, hindering local food production in developing nations and increasing

dependence on global imports.

E. Discussion

The modest employment benefits from capital-intensive dairy CAFOs do not outweigh the many

direct and indirect costs dairy production imposes upon SJV communities. Though the statewide

economic benefits may be large, from the local perspective, the costs of dairy production in the SJV

outweigh the benefits. Additionally, national and global costs of industrial dairy production likely

outweigh statewide economic benefits.

Comparing census demographic data to the rest of California and the distribution of dairy CAFOs,

we see that the costs of dairy production are imposed upon a disproportionately poor, non-white,

undereducated, and non-English speaking population, raising important questions about

environmental justice in central California. Though this cost would be difficult to quantify, adversely

affecting a politically disenfranchised community for the sake of efficiency is unacceptable when

concerned with issues of equity.

The most basic problem with dairy CAFOs is a market failure in the form of production

externalities borne by local communities that are politically disenfranchised. The industrialization of

dairy production and the resultant nutrient concentration impose economic, public health, and

quality of life costs upon CAFO communities, none of which are considered in production decisions

on-farm. As such, milk is produced in quantities above the social optimum, contributing to

environmental degradation and negatively affecting local health and quality of life. Therefore, action

must be taken at the local, state, and federal level to ensure that SJV communities enjoy

environmental justice and protection from the costs imposed upon them by dairy CAFOs.

F. Criteria for Policies Addressing Local Externalities

While the focus of this paper is on the local benefits and costs of dairy CAFOs in the San Joaquin

Valley, local solutions may have regional, national, and even statewide consequences. Policy

alternatives addressing the externalities imposed by dairy CAFOs upon SJV communities should

ideally meet the following four criteria:

1. Increase Local Economic Benefit

The production externalities from dairy production in the SJV lead to a transfer of wealth from a

traditionally impoverished region to more affluent citizens. Local economic benefit could be

increased by internalizing the societal costs of dairy production to dairy producers, or by keeping

dairy revenues in production regions. Facing higher costs of production, dairies would have the

incentive to decrease herd size and production scale, thereby decreasing production externalities.

2. Improve Community Health


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The direct and indirect effects of CAFO pollution on public health have serious social and

economic consequences for SJV communities. Community health could be improved by reducing

pollution levels and internalizing production externalities.

3. Increase Local Quality of Life

Odors, air quality, impeded community development and poor health impair quality of life among

CAFO neighbors. Decreasing pollution levels could increase local quality of life.

4. Increase Equity

Dairy CAFOs in the SJV disproportionately affect poor, non-white, rural communities. Equity for

these communities could be improved by providing accessible avenues of reprieve for underserved

communities.

V. Recommendations

Given the traditional zero-discharge requirements for agriculture and the accompanying policy

regime, the external effects of dairy production upon local communities may seem surprising. Part

of the problem is due to California’s long standing exemption for agricultural sources of pollution,

just recently revoked.

Internalizing external costs of dairy production to dairy producers is, in economic terms, the most

efficient way to mitigate the problems caused by CAFOs in SJV communities. The effect would be

to decrease milk production to the point at which social cost was equal to demand, since the

production costs paid by dairies would be higher. This type of a regulatory scheme would be

unpopular on its face, as California is traditionally protective of agricultural interests. However, the

policies for internalization are in place already. The main problem is surveillance and

implementation-- policies simply are not being enforced, due in large part to lack of information,

lack of resources, and lack of will.88

Though violations of environmental justice are not directly addressed by the following

recommendations, enforcing CAFO regulations would contribute to the protection of these

disenfranchised communities-- something that has not yet been done in the SJV.

A. San Joaquin Valley Policy Recommendations

• In order to enforce federal and state standards (and protect the health and quality of life

of SJV citizens), the CVRWQCB and SJVUAPCD should develop and implement a

strategy to collect and archive all relevant data about existing SJV dairy CAFOs and

associated manure storage structures, application fields, and production practices.

One of the biggest challenges facing regulatory agencies in the SJV today is an information

asymmetry. Inspection and enforcement activities are conducted mainly as a response to local

88 Interview with Deanne Meyer. April 2, 2007.


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complaints. Given that SJV communities are politically disenfranchised and more likely to have low

English proficiency, complaints are less likely.

No sufficient data exists to determine if current dairies are in compliance with water and air

protection regulations. While dairies may be aware of compliance issues or sub-standard waste

management, the organizations charged with regulating these dairies are not. This creates moral

hazard for dairies to pollute locally without reporting.

The problem is not that policies are lacking, but information for enforcing the existing policies is

non-existent. For example, the CVRWQCB does not know which lagoons in the region are lined

with clay and gravel soils that meet state standards. This lack of information presents a significant

challenge to effectively enforcing water protection policies. Therefore, local priority should be given

to collecting the information needed to determine compliance.

Once compliance or non-compliance is determined for each facility, the local air and water quality

boards will have the ability to enforce discharge requirements, improving local health, quality of life,

and promoting equity.

• In order to address resource and staff shortages, as well as enforce existing regulations,

CVRWQCB, SJVUAPCD, and local zoning/development boards should actively partner

with one another and with industry and related support organizations (such as CDQAP)

to enforce policies.

When the water board requested ROWDs from the region’s dairies, they enjoyed a 98% response

rate thanks in large part to the outreach efforts of the CDQAP, which conducted over thirty free

short-courses and workshops to assist dairies with applications. Despite the service provided by

organizations such as CDQAP, which assist with voluntary compliance and self-regulation, there is a

lack of cooperation between agencies and outreach service providers.

Given the evidence of non-compliance with zero discharge requirements, and considering the lack

of resources available to these agencies (in the form of time, staff, and technology) relative to the

time effective enforcement would require (there are over 1000 dairies in the SJV alone), a

cooperative enforcement and monitoring strategy would help meet regulatory needs. Additionally,

agency cooperation would help to clarify existing confusion regarding jurisdiction and process (e.g.

Meyer noted that no agency-- local or regional-- currently claims responsibility for lagoon

composition analysis or enforcement89). The failure to enforce policies has serious consequences for

equity in the SJV. Partnering to enforce CAFO standards would promote environmental justice by

protecting SJV communities. Additionally, enforcement of CAFO regulations may increase local

economic benefit (to the extent the enforcement necessitates smaller-scale production which may

lead to local input purchases), improve community health, and improve quality of life.

89 Interview with Deanne Meyer. April 2, 2007.


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• In order to stop additional growth of the dairy industry in a region already past its

pollution carrying capacity, institute a regional moratorium on new dairy CAFOs.

The PPIC predicts that by 2040 the population of California will grow from its current level of 35

million people to somewhere between 45-55 million people.90 The SJV is predicted to be one of the

fastest growing regions in the state. Population growth in the SJV will likely lead to more

urbanization on agricultural land and further consolidation of dairies. The predicted population

growth in the SJV will exacerbate the problems discussed in this paper, as more people will be

adversely affected by dairy externalities. As population density increases, so will the public health

costs associated with dairy emissions and discharges.

Available evidence suggests that the SJV is already well beyond its dairy-cow carrying capacity.

Geographic features in the region, combined with the dense proliferation of dairy cows, have

created an environmental and public health crisis that must first be addressed by stopping the flow

of CAFOs into the region. The CVRWQCB could implement this policy suspending issuance of

new NPDES and WDR permits for new dairies. Though this policy may not increase local

economic benefit, it would prevent further declines in local health, quality of life, and process equity.

B. California Policy Recommendations

• To promote voluntary compliance with California water and air pollution regulations, set

achievable, understandable, and steady-state goals to reduce risk.

Dairy producers are hesitant to make large process improvement investments because of the

uncertainty associated with current regulations. For this reason, the number of dairies using the

latest pollution-mitigation technologies “can be counted on one hand.”91 This may be one

explanation for the remarkably high amount of pollution in the SJV.

According to Dr. Deanne Meyer, a UC Davis Cooperative Extension specialist who works directly

with California dairy operators, the biggest incentive for farmers to invest in pollution reduction

technologies would be to “get rid of the moving targets.” WDR standards and air pollution

standards have consistently changed at both the local and state levels. Says Meyer, “We need a

stepwise process to document benchmarks for dairies to meet standards. The regulatory agencies

must be firm and consistent, or they may as well not issue permits.” Dairy operators are hesitant to

invest in expensive pollution reduction technologies when they are not certain that the technology

will help them achieve compliance.

For example, installing a methane digester that produces energy from waste with a combustion

engine may mean that the dairy will be regulated as an air pollution point source (in addition to NPS

regulation). This is clearly a disincentive for innovation. A further complication arises from the

90 Teitz, et al. 2005. pp.v. 91 Interview with Deanne Meyer. April 2, 2002.


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separate regulation of air and water contamination. Measures taken to reduce water contamination

by reducing nutrient content (by allowing waste to volatilize in holding structures, for example)

often increase emissions to the atmosphere, and vice versa. Therefore, many producers are hesitant

to invest heavily in mitigation technologies that could bring them into conflict with other pollution

regulations.92 This risk aversion is especially salient in a commodity industry, where only the most

efficient farms are profitable. Reducing risk for farmers could substantially improve prospects for

innovation.

The tradeoff with this policy option comes with the reality that nutrient emissions rates are not

constant over time or between operations. Soil absorption capacities, acreage, lagoon lining

composition, non-organic content, and manure nutrient concentration (varying with diet) affect the

composition of waste water and manure. Therefore, having flexible agronomic rates of application

may provide some benefits. However, given the limitations in current technology, available data,

agency resources, and the political climate, it is recommended that a non-moving standard be

established for farmers to incentivize investment in mitigation technologies that may improve local

health and quality of life.

• To promote innovation, provide regulatory “safe harbor” for dairies that implement

approved technologies.

For the reasons discussed above, reducing risk for farmers trying innovative mitigation technologies

would encourage implementation of potentially helpful mitigation technologies. Dairies that attempt

to implement approved technologies but miss emissions targets as a result should be granted safe

harbor from serious legal consequences, perhaps in the form of a reasonable grace period for

process improvement. To the extent that safe-harbor leads to process innovations, local health and

quality of life may be improved.

• To speed up research and development for dairy technology, fund research for new

pollution mitigation and monitoring technologies.

Current BACT air control standards, CMPs, and other mitigation technologies were recommended

largely in the absence of concrete empirical evidence of their effectiveness. For example, the regional

water boards and state are not certain which organic compounds are precursors to ozone, and

therefore mitigation policies are implemented independent of this consideration. Technologies for

waste management and recycling are somewhat archaic. There are many research and development

opportunities in the field of livestock waste management. The state should incentivize or fund such

research.

This alternative would have small short-term benefits for SJV residents, but could lead to major

long-run benefits if technologies were developed to lessen the negative externalities of industrial

dairy farming.

92 Aillery et al. 2005.


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C. Federal Policy Recommendations

• In order to enforce the expanded federal CAFO regulations, develop and implement a

strategy for granting permits to CAFOs and enforcing discharge requirements. Should

additional resources be necessary to effectively enforce CAFO regulations, state

regulatory agencies (such as the CVRWQCB) should have access to such resources,

contingent upon performance.

The General Accounting Office (GAO) reported U.S. EPA failures to properly implement and

enforce state NPDES permitting programs. GAO cited two fundamental problems with EPA

implementation. The first was the failure to require permits for almost 60% of CAFOs with more

than 1000 animal units (through various exemptions), and the second was failure to ensure that state

permitting programs properly enforced regulations.93

U.S. EPA resources for enforcement of the CWA were insufficient even before the increase in

regulated facilities. U.S. EPA must ensure that states delegated the responsibility of enforcing CWA

standards meet federal requirements. More resources or an improved strategy for standard

enforcement will be essential to the program’s success.

Enforcement of federal standards would improve health and quality of life in the SJV, as well as

improve current violations of environmental justice. To the extent that enforcement of policies leads

to smaller, more numerous dairy farms, the local economic benefit in the long run could be

substantial.

VI. Recommendations for Further Research

Available evidence strongly suggests that from the local perspective, CAFO costs to the economy,

health, and quality of life outweigh any inherent benefits. The above examination of SJV

community demographics and CAFO distribution raises important concerns about environmental

justice in the region. Recommendations for further research include:

• A statewide analysis of trends in demographics and CAFO distribution to further examine the

relationship between CAFO location and community demographics.

• Systems analysis research regarding CAFO waste cycles will be imperative to the future of the

California dairy industry and the well being of SJV residents. If the current level of production is

sustained, new mitigation and systems technologies will be essential.

Oversight and enforcement of water and air regulations must be improved at the local, state and

federal levels, especially considering the predicted trajectory of the SJV toward urbanization and

population growth. Until dairy operators incur the total societal costs of production, the negative

93 General Accounting Office. Increased EPA Oversight will Improve Environmental Program for Concentrated Animal

Feeding Operations. 2003. GAO-03-285. pp. 6.


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environmental externalities described above will continue to negatively impact the citizens of the

SJV. Joint strategies for enforcement will be essential to the success of mitigation policies.


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List of Acronyms

AFO Animal Feeding Operation

CAFO Concentrated Animal Feeding Operation

CAPCOA California Air Pollution Control Officers Association

CARB California Air Resources Board

CCC California Coastal Commission

CDQAP California Dairy Quality Assurance Program

CMAB California Milk Advisory Board

CSWRCB California State Water Resources Control Board

CVRWQCB Central Valley Regional Water Quality Control Board

CWA Clean Water Act

NMP Nutrient Management Plan

NPDES National Pollutant Discharge Elimination System

NPS Non Point Source

NOx Nitrogen Oxide

PM Particulate Matter

ROWD Report of Waste Discharge

RWQCB Regional Water Quality Control Board

SJV San Joaquin Valley

SJVAB San Joaquin Valley Air Basin

SJVUAPCD San Joaquin Valley Unified Air Pollution Control District

SWRCB State Water Resources Control Board

TMDL Total Maximum Daily Load

VOC Volatile Organic Compound

WDR Waste Discharge Requirement


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Works Cited Data

California Health Interviews Survey. http://www.chis.ucla.edu/

Central Valley Water Quality Control Board, Fresno and Sacramento Offices. Report of Waste Discharge Applications.

U.S. Census, 2000. Summary File 3.

Interviews and Correspondences

Meyer, Deanne. Ph.D.,Cooperative Extension Specialist, Livestock Waste Management. University of California, Davis, in person, April 2, 2007.

Pollan, Michael. Professor of Journalism. University of California, Berkeley, in-person and via email. February through March, 2007.

Robinson, Peter H. Ph.D., Cooperative Extension Specialist, animal nutrition. University of California, Davis, via telephone, February 27, 2007.

Publications

Aillery, Marcel, Noel Gollehon, Robert Johansson , Jonathon Kaplan, Nigel Key, and Marc Ribaudo. Managing Manure in Improve Air and Water Quality. September 2005. USDA Economic Research Report 9. Baldassare, Mark. Special Survey of the Central Valley. June 2006. Public Policy Institute of California. Blayney, Don P. The Changing Landscape of U.S. Milk Production. United States Department of Agriculture Statistical Bulletin 978. June 2002.

California Air Pollution Control Officers Association (CAPCOA), White Paper on SB 700. April 2004.

California Dairy Research Foundation. California Dairy Facts. http://www.cdrf.org/content.asp?contentID=55. Accessed April 5, 2007. California Department of Food and Agriculture. California Agricultural Resource Directory, 2006. January 2007. California Milk Advisory Board. How California Created the Dairy Industry of the Future. 2005.

Committee of Experts on Dairy Manure Management. Managing Dairy Manure in the Central Valley of California. Revised June 2005. University of California Division of Agriculture and Natural Resources. California Partnership for the San Joaquin Valley. Overview Report for the Air Quality Work Group. Accessed April 15, 2007. http://www.bth.ca.gov/capartnership/pdf/AirQualityandEnvironmentalProtection.pdf


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California State Water Resources Control Board. Non Point Source Management Plan, Section II Five Year Implementation Plan. 2003. Cole, Dana, Lori Todd and Steve Wing. Concentrated Swine Feeding Operations and Public Health: A review of Occupational and Community Health Effects. 2000. Environmental Health Perspectives. 108(8). Copeland, Claudia. Animal Waste and Hazardous Substances: Current Laws and Legislative Issues. 2006. CRS Report for Congress. RL-33691. Cowan, Tadlock. California’s San Joaquin Valley: A Region in Transition. 2005. CRS Report for Congress. Dairy Permitting Advisory Group. Recommendations to the San Joaquin Valley Air Pollution Control Officer Regarding Best Available Control Technologies for Dairies in the San Joaquin Valley. January 31, 2006. Dairy Subcommittee of the San Joaquin Unified Air Pollution Control District. Air Emissions Action Plan for California Dairies. 2003. Donham, Kelley, Steven Wing, David Osterberg, Jan Flora, Carol Hodne, Kendall Thu, and Peter Thorne. Community Health and Socioeconomic Issues Surrounding Concentrated Animal Feeding Operations. February 2007. Environmental Health Perspectives. 115(2). Dryer, Jerry. The Economic Impact of the California Dairy Business. September 2005. California Milk Advisory Board. Environmental Law Institute. State Regulation of Animal Feeding Operations: Seven State Summaries. 2003. Environmental Protection Agency. National Pollutant Discharge Elimination System Permit Regulation and Effluent Limitation Guidelines and Standards for Concentrated Animal Feeding Operations (CAFOs). February 12, 2003. Federal Register. Volume 68. No. 29. Environmental Protection Agency. NPDES Permit Regulation and Effluent Limitation Guidelines and Standards for Concentrated Animal Feeding Operations; Final Rule.40 CFR Parts 9, 122, 123, and 412. Fenske, Richard. Incorporating Health and Ecologic Costs into Agricultural Production. 2002. Environmental Health Perspectives. 110(5). The Fresno Bee. The Last Gasp. December 15, 2002. http://www.valleyairquality.com/ Accessed April 15, 2007. Goldschmidt. Agribusiness and the rural community. 1978. As You Sow: Three Studies in the Social Consequence of Agribusiness. Montclair, New Jersey: Allenheld, Osmun & Co. Gollehon, Noel, Margriet Caswell, Marc Ribaudo, Robert Kellogg, Charles Lander, and David Letson. Confined Animal Production and Manure Nutrients. 2001.USDA Economic Research Service. AIB-771.


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Greenwald, Michelle. Real California Cheese: It’s the Cheese. Columbia Business School. 2005. Horrigan, Leo, Robert Lawrence, and Polly Walker. How Sustainable Agriculture Can Address the Environmental and Human Health Harms of Industrial Agriculture. May 2002. Environmental Health Perspectives. 110(5). Kilpatrick, John. Concentrated Animal Feeding Operations and Proximate Property Values. 2001. The Appraisal Journal. LXIX(3). Kirkhorn, Steven and Vincent Garry. Agricultural Lung Diseases. 2000. Environmental Health Perspectives. 108(4). Kirschten, Dick. Inviting Workers, Importing Poverty. February 27, 1999. National Journal. 31(9) MacCannell, Dean. Industrial Agriculture and Rural Community Degradation. 1988. Agriculture and community change in the U.S.: The Congressional Research Reports. Miller, James and Don Blayney. Dairy Backgrounder. July 2006. Economic Reasearch Service. United States Department of Agriculture. Mirabelli, Maria, Steve Wing, Stephen Marshall, and Timothy Wilcosky. Race, Poverty, and Potential Exposure of Middle-School Students to Air Emissions from Confined Swine Feeding Operations. Environmental Health Perspectives. 114(41). Office of Wastewater Management. State Compendium, Programs and Regulatory Activities Related to Animal Feeding Operations. U.S. Environmental Protection Agency. Osterberg, David and David Wallinga. Addressing Externalities from Swine Production to Reduce Public Health and Environmental Impacts. October 2004. American Journal of Public Health. 94(10). Palmquist, R, F. Roka, and T. Vukina. Hog operations, environmental effects, and residential property values. 1997. Land Economics. 73. pp. 114-124. Perez, Miguel, and Kathleen Curtis. Healthy People 2010: A 2003 profile of health status in the Central San Joaquin Valley. 2003. California State University, Fresno. Ribaudo, Marc. Managing Manure: New Clean Water Act Regulations Create Imperative for Livestock Producers. 2003. Amber Waves. 1(1). Ribaudo, Marc, Jonathon Kaplan , Lee Christensen, Noel Gollehon, Robert Johansson, Vince Breneman, Marcel Aillery, Jean Agapoff, and Mark Peters. Manure Management for Air Quality: Costs to Animal Feeding Operations of Applying Manure Nutrients to Land. June 2003. USDA Economic Research Report 824. Ribaudo, Marc and Marca Weinberg. Improving Air and Water Quality can be Two Sides of the Same Coin. September 2005. Amber Waves. 3(4).


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San Joaquin Valley Unified Air Pollution Control District. Rule 4550. Adopted May 2004. San Joaquin Valley Unified Air Pollution Control District. Rule 4570. Adopted June 2005. Sporleder, T. Ohio Food Income Enhancement Program. 1997. Agricultural, Environmental, and Development Economics Department. Ohio State University. Teitz, Michael, Charles Dietzel, and William Fulton. Urban Development Futures in the San Joaquin Valley. 2005. Public Policy Institute of California. Thu, K. Public Health Concerns for Neighbors of Large-Scale Swine Production Operations. 2002. Journal of Agricultural Safety and Health. 8(2). U.S. Department of Agriculture and U.S. EPA. Unified National Strategy for Animal Feeding Operations. 1999. U.S. EPA. Compliance Website. April 14, 2007. http://www.epa.gov/compliance/environmentaljustice U.S. General Accounting Office. Increased EPA Oversight will Improve Environmental Program for Concentrated Animal Feeding Operations. 2003. GAO-03-285. U.S. Government Accountability Office. USDA Should Improve its Process for Allocating Funds to States for the Environmental Quality Incentives Program. 2006. GAO-06-969. Waterkeeper Alliance et al. v. EPA. 399 F.3d 486 Weida, William. Comments on the Potential Regional Economic Effects of Large Feedlots. 2001. A GRACE Factory Farm Project Report. Weida, William. Considering the Rationales for Factory Farming. March 29, 2004. Presented at: Environmental Health Impacts of CAFOs: Anticipating Hazards, Searching for Solutions. Wing, Steve and Susanne Wolf. Intensive Livestock Operations, Health, and Quality of Life among Eastern North Carolina Residents. 2000. Environmental Health Perspectives. 108(3).


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Appendix A: Statistical Analysis and Regression Results Graphic Analysis of Trends Simple scatter-plots of the natural log of cows per block group (with cows > 0) versus block group data on non-white population proportion, percentage households in poverty, and population density reflect that population density is the only variable with an obvious correlation to ln(cows).

0.00

2.00

4.00

6.00

8.00

10.00

12.00

0.0000 0.2000 0.4000 0.6000 0.8000 1.0000

ln(c

ow

s)

Non-White Population Proportion

0.00

2.00

4.00

6.00

8.00

10.00

12.00

0.0000 0.1000 0.2000 0.3000 0.4000 0.5000

ln(c

ow

s)

Poverty Rate


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Multiple Regression Analysis Using data from the US Census 2000, the Central Valley Regional Water Quality Control Board, and

information calculated using GIS spatial analysis tools, four different regression models were

specified to examine the relationship between total cows per block group and various demographic

characteristics of the San Joaquin Valley.

Simple multivariate regressions with total cows per block group as the dependent variable, and

population density, non-white population, and households in poverty as the explanatory variables

were run including all block groups and including only block groups with > 0 cows (Regressions 1-

2), in order to determine how the relationship between the variables changed when excluding the

population-dense urban centers with zero cows. Including all block groups resulted in a highly

significant coefficient for population density, suggesting that the urban centers are a major driver of

the relationship between population density and total cows seen in Regression 2.

Models with the natural logs of total cows and population density as the dependent variable were

specified (Regressions 3-4), reflecting that the total cows and population density variables are counts

(over a specific geographic area), or prevalence rates, indicating that the Poisson distribution may

better fit the data. Examining the relationship between population density and total cows in both

directions was important to understanding the degree to which large herd sizes keep population

density low, and vice versa. The relationship appears to run in both directions.

Regression 1: Simple Multivariate Regression (block groups with total cows >0)

�� = � + �� + ��ℎ�� + �� + ! Where i denotes block group, n=201

0.00

2.00

4.00

6.00

8.00

10.00

12.00

0.0000 0.0005 0.0010 0.0015 0.0020

ln(c

ow

s)

Population Density (ppl/sq meter)


Page | 47

Coefficient Standard Error T-Score P-Value

Population Density -10522974 4033819.12 -2.6086875 0.0098

Non-White Population -1358.04779 5976.072198 -0.22724755 0.8207

Poverty 384.2769 11605.3 0.033112 0.9736

Constant 8420.265 1982.643

Regression 2: Simple Multivariate Regression (all block groups)

n = 2285

Regression 3: Poisson Regression (block groups with total cows > 0)

�� = � + �� + ��ℎ�� + �� + !


Population Density -2601.1467 508.662615 -5.1136975 0.0000

Non-White Population -0.16819978 0.753579776 -0.22320103 0.8238

Poverty 0.190625 1.463423 0.13026 0.8965

Constant 8.159321 0.25001

Regression 4: Natural Log of Population Density as Dependent Variable (block groups with

total cows > 0)

�� = � + ��ℎ�� + �� + �� + !


Non-White Population 1.01030151 0.71023894 1.42248116 0.1565

Poverty -4.08166213 1.35877821 -3.0039208 0.0030

Total Cows -4.67E-05 8.47E-06 -5.513983762 0.0000

Constant -9.986918 -5.513983762


Population Density -457253.63 55225.9884 -8.2796821 0.0000

Non-White Population 78.3528658 490.1616964 0.159851058 0.8731

Poverty 1154.326 796.4123 1.449408 0.1474

Constant 1141.991 166.0516


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Appendix B: Additional Maps Figure 8: Northern SJV Population Density


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Figure 9: Southern SJV Population Density


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Figure 10: Northern SJV Non-White Population


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Figure 11: Southern SJV Non-White Population


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Figure 12: Northern SJV Poverty Rate


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Figure 13: Southern SJV Poverty Rate

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