Last week, Mark Udall sent a letter to U.S. Environmental Protection Agency Administrator Lisa Jackson asking her to consider the impact regulations governing dust could have on rural communities, as her agency begins reviewing air-quality standards.
The EPA is required to set air-quality standards for fine and coarse particulate matter (PM), which includes dust, to protect public health; EPA is currently reviewing those standards for revision. However, Udall noted that Colorado's cattle producers, corn growers, and other farmers and ranchers, are concerned that tighter dust regulation could become overly burdensome and expensive if they are required to pave dirt roads or pay for dust mitigation.
While Udall respects the EPA's responsibilities under the Clean Air Act, he wants to ensure any revised policies take into account rural realities and the conservation efforts that farmers, ranchers and rural residents take to mitigate dust as a constant part of rural living.
"[R]ural Coloradans--namely farmers and ranchers--have a deep understanding of the need for conservation on their lands as a means of responsible mitigation of dust from on-farm activities, including better tilling and crop rotation practices, along with other means," Udall wrote to the EPA. "Nevertheless, no matter how many precautions we take on the windswept plains and other areas of Colorado, dust is a perpetual part of life on this arid landscape."
Following is the full text of the letter Udall sent to the EPA:
March 11, 2011
The Honorable Lisa Jackson
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
Dear Administrator Jackson:
I write you to share the concerns of constituents in Colorado regarding the pending review of National Ambient Air Quality Standards (NAAQS) for coarse particulate matter (PM). Specifically, I ask that you give serious consideration to any impact that a more stringent NAAQS for coarse PM may have on Colorado's farming and ranching communities.
As I understand, on February 24, 2009 a U.S. Court of Appeals for the D.C. Circuit decision granted petitions challenging certain aspects of the Environmental Protection Agency's (EPA) revised NAAQS, which, in part, contributed to the EPA expediting its review of these standards. I understand the EPA's requirements to review the NAAQS based on robust scientific methods and its responsibilities under the Clean Air Act; however, I am aware of concerns that a decision to tighten coarse PM standards may have adverse implications for rural Colorado.
In the arid West, dust is part of life, and rural Coloradans understand the health risks when adequate measures are not taken to reduce wind erosion. Many Coloradans, especially on the Eastern plains, recall the experiences of the Dust Bowl of the 1930s when black storms enveloped entire communities, choked livestock and wreaked havoc on crops and on our rural economy. Having learned from this experience, rural Coloradans--namely farmers and ranchers--have a deep understanding of the need for conservation on their lands as a means of responsible mitigation of dust from on-farm activities, including better tilling and crop rotation practices, along with other means. Nevertheless, no matter how many precautions we take on the windswept plains and other areas of Colorado, dust is a perpetual part of life on this arid landscape.
I paint this picture because many Coloradans are concerned that the implementation of a more stringent standard will have negative implications on rural communities and businesses. They are concerned that EPA regulations will lead to state implementation of a revised standard that may require them to pave gravel and dirt roads or use scarce water resources to spray roads and dirt lots. At a time when rural Colorado counties are facing increasingly tough economic realities, I ask that you take into account the unique aspects of rural life should you make a final determination on updating coarse PM standards.
Rural Coloradans are as concerned as anyone for their health and that of their neighbor and understand the benefits of dust mitigation practices that can improve crop yields. Still, it is important to note that there are stark differences between life in urban and rural areas.
As I mentioned, it is important that the NAAQS are based on sound science and that we adequately protect human health and welfare; however, we cannot ignore the realities of rural life in any final decision to update the NAAQS. I look forward to learning of your progress in reaching out to rural America. Should you have any questions, please do not hesitate to contact me or my staff at 202-224-5941.