Superfund Docket
Environmental Protection Agency
Mailcode: 5202T
1200 Pennsylvania Ave., NW
Washington, DC 20460

RE: My comments on Docket ID No. EPA-HQ-SFUND-2005-0013 (Ammonia pollution)

Dear EPA,

As an American concerned with the health and safety of my family and of all our citizens, I very strongly oppose the National Chicken Council, National Turkey Federation, and U.S. Poultry and Egg Association’s Petition for Exemption from EPCRA and CERCLA Reporting Requirements for Ammonia from Poultry Operations. The EPA should uphold its responsibility to protect the health of Americans and of our environment by denying the petition.

Federal reporting requirements under Section 104 of the Emergency Planning and Community Right to Know Act (EPCRA) and Section 103 of the Comprehensive Environmental Response, Compensation Liability Act (CERCLA) are triggered only when emissions exceed a set threshold and therefore pose a risk to nearby communities. For a poultry facility, reporting requirements would kick in for releases of 100 pounds or more of ammonia within a 24-hour period.

The reporting requirements under EPCRA and CERCLA are absolutely reasonable and necessary measures to protect the public health. Scientific analysis has shown that the livestock sector produces more ammonia than any other industry in the country, accounting for 73 percent of ammonia emissions each year. Respiratory ailments are among the human health problems associated with ammonia releases from Concentrated Animal Feeding Operations (CAFOs). Ammonia can harm cilia in the respiratory system, narrow airways, inflame mucous membranes, and impair the ability to clear particulate matter from the airways.

The poultry industry’s significant contribution to this ammonia pollution comes almost exclusively from CAFOs, large-scale facilities that may house tens or even hundreds of thousands of birds. These massive operations accumulate large quantities of excrement in a concentrated area and, when not properly managed, can pose a significant risk to the public health. For example, one concentrated egg-producing facility in Ohio released 800 tons—or 1,600,000 pounds—of ammonia into the air in one year. This amount and the amount of ammonia released by similar operations are comparable to or greater than the ammonia emissions of some of the nation’s largest factories. Therefore, to exempt poultry farms from reporting requirements that apply to other industries would be an egregious violation of the right of all Americans to be protected from dangerous and damaging emissions. This proposed exemption should be unconditionally rejected.

Thank you very much for considering my comments. I will join millions of Americans in closely following your actions in this vital matter.

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