The Environmental Protection Agency (EPA) announced an effort to initiate air emissions regulation for livestock farms, including dairy, on a national basis. EPA acknowledged that a lack of research prevented the development of appropriate regulatory thresholds and guidelines. Curt Gooch and Karl Czymmek, PRO-DAIRY team members, alerted the dairy industry nationwide and worked with dairy producer groups in New York state and elswhere to help undertand the issues and implications of EPA`s intentions.

The issue arose in 2004 when an EPA official spoke to dairy producers at a conference in Syracuse, NY, indicating that EPA was about to offer a legal agreement to dairy and livestock producers, but that dairy producers were not at the negotiating table. Curt Gooch followed up on this issue by contacting EPA for further information. Gooch recognized that this was a serious issue and that dairy need to be alerted as quickly as possible if the industry was going to have any say in how this issue would unfold. Thousands of dairy farms nationally could be impacted.

Gooch and Czymmek worked closely with dairy organizations such as the Northeast Dairyproducers Association, Western United Dairyman, Professional Dairy Managers of Pennsylvania, New York and Pennsylvania Farm Bureau, and Dairy Business Association of Wisconsin, and attornies to evalaute the situtaion, including a 60 page legal document that EPA planned to use to "settle" with dairy producers. Gooch and Czymmek organized two national conference calls with dairy producers, EPA and industry representatives to provide information. They also visited EPA staff in Washington, DC, including deputy administrator Tom Skinner to discuss the issue and to educate EPA about the dairy industry.

Working with private attornies and EPA, we were able to develop and submit industry comments to EPA, some of which were incorporatesd into the final legal document used. As a direct result of our work, over 600 dairies nationally decided to sign the "consent agreement" to receive protection from EPA for any potential air emissions violations while a national air emissions research project is ongoing. New York state had the highest participation rate of any state in the U.S., with just over 150 dairies participating. California and New Mexico had nearly as many. Without the efforts of Gooch and Czymmek, the dairy industry would have missed the opportunity to participate in the agreement and EPA would have moved ahead to regulate the industry without industry input, participation, or data.

Curt Gooch