Dairy Air Emissions/CAFOs Environmental Organizations Petition Oregon Environmental Quality Commission to Promulgate Rule Requiring Quantification/Regulation

Food and Water Watch and 21 other environmental organizations (collectively, "FWW") filed an August 17th document with the Oregon Environmental Quality Commission (“EQC”) titled:

Petition to Adopt a Dairy Emissions Program to Quantify and Regulate Large Dairy CAFO Air Emissions (“Petition”)

The organizations joining the Petition include:

• 350 Eugene
• 350 Deschutes
• Animal Legal Defense Fund
• American Society for the Prevention of Cruelty to Animals (ASPCA)
• Farm Forward
• Farm Sanctuary
• Friends of the Columbia Gorge
• Beyond Toxics
• Center for Biological Diversity
• Center for Food Safety
• Columbia Riverkeeper
• Comunidades Amplifying Voices for Environmental and Social Justice
• Friends of Family Farmers
• Mercy for Animals
• Northwest Environmental Defense Center
• Oregon Physicians for Social Responsibility
• Pendleton Community Action Alliance
• Environment Oregon
• Humane Voters Oregon
• Public Justice Foundation
• World Animal Protection

The Petition requests that EQC require the Oregon Department of Environmental Quality (“DEQ”) to address air emissions from what are described as large dairy concentrated animal feeding operations (“CAFOs”).

FWW argues that a dairy emissions program should be adopted to quantify and regulate CAFOs because DEQ is stated to neither monitor nor regulate such emissions through its Air Contaminant Discharge Permit program.

FWW’s Petition includes the following factual arguments in support of its Petition:

• Failing to Immediately Regulate Dairy CAFO Air Emissions Threatens Public Health
• Failing to Immediately Regulate Dairy CAFO Air Emissions Exacerbates Environmental Injustices Across the State
• Failing to Immediately Regulate Dairy CAFO Air Emissions Poses a Direct and Serious Threat to Oregon’s Environment
• Failing to Immediately Regulate Dairy CAFO Air Emissions Exacerbates Inhumane Living Conditions for Farmed Animals
• Failing to Immediately Regulate Dairy CAFO Air Emissions Jeopardizes the Economic Livelihoods of Oregon’s Few Remaining Small and Mid-sized Dairy Farms

Legal arguments outlined in the Petition include:

• EQC Has Broad Authority to Regulate State Air Quality
• EQC Has Express Authority to Adopt Air Quality Rules Applicable to Agricultural Sources

EQC has 90 days to formally respond to the Petition by either denying FWW’s request or initiating rulemaking proceedings.

A copy of the Petition, which also includes the proposed rule language, can be downloaded here.