Fecal Dust in West Texas by Emma Rose Shore

West Texas, especially the 13th district and the surrounding area, has long been afflicted by a pollutant that regulators have chosen to ignore. While it may seem a quaint issue, fecal dust from concentrated animal feeding operations has a huge impact on the respiratory health of those living in the region.[1] The economy of the region is centered around the cattle industry, with seemingly endless cow pastures. However, the aridity of the region has dried the fecal matter from these cows and sent it airborne, into neighboring communities and residents’ lungs. This cloud settles over towns in the afternoon, permeating the air with a strong odor and thick haze that strains breathing.

The true danger of this haze is often less visible: the inhalation of ammonia and small particulates, which has been proven to have serious health outcomes. Some of the possible health impacts are asthma, heart conditions, difficulty breathing, and premature death in citizens with heart or lung disease[2]. In West Texas, there has been a serious lack of data and study on the link between fecal dust and asthma, because fecal dust levels are not being monitored. Epidemiological studies that have been conducted in the area have shown that the levels of asthma, heart conditions, and premature deaths are disproportionately large, and the region has the most instances of asthma in the state.[3] One study found that doubling livestock production in an area caused a 7.4% increase in infant mortality due to respiratory disease.[4] Another found that children living in the region were at a far higher risk of developing asthma.[5]

While ammonia and small particulates are generally regulated by the EPA, in Texas manure is not listed as a pollutant and does not count toward a company’s quota.[6] This allows cattle companies to pollute freely and indiscriminately, without facing the consequences other industries are subject to. Even worse, the level of fecal dust is the air is not monitored so doctors and health experts have no way of knowing the amount of ammonia and other dangerous particulates that people are inhaling. Despite repeated complaints from residents of the area, the Texas Department of State Health still does not monitor or test the impact of living near CAFOs or collect data on fecal dust output.[7] The agency’s monitors are conspicuously absent from the areas most affected by CAFO dust, and studies have had to rely on independently collected data.

I propose that ammonia and particulates originating from cow manure should be classified as a pollutant, and ammonia should be regulated as a criteria pollutant under the Clean Air Act, Sections 108 and 109. This will allow the EPA to set a National Ambient Air Quality Standard limiting the amount of ammonia allowed in the air.[8] To enforce the EPA’s regulations, monitoring stations should be set up in the 13th district and surrounding regions to collect data on levels of ammonia. This data should be made freely available for researchers and doctors and should also be used to enforce regulations on cattle ranchers. West Texas is fairly unique in facing this issue, given the density of cattle and the region’s dry environment, so any solution would be unprecedented. Because taxes are politically unpopular in Texas, especially in regard to the cattle industry, which is heavily protected by legislators who take large campaign contributions from the cattle industry,[9] I propose that a cap-and-trade program on waste production would be the best option to limit the fecal dust in the air, with the initial permits being allocated according to historic pollution levels through a grandfathering system. Cap-and-Trade programs can approximate the most economically efficient solution while avoiding the label of “tax”. Cattle ranchers are able to abate airborne fecal dust through manure watering, conversion to fertilizer, and more frequent raking of the fields. The cap-and-trade program would incentivize ranchers to abate more of their pollution, as long as the abatement cost is lower than the market rate of a permit.

The major obstacle of this solution is measuring how much fecal dust each farm is outputting, as ranches are often adjacent and fecal dust is airborne. We should calculate their waste level by multiplying the number of cows by a coefficient that is determined by the conditions of their ranch and the abatement efforts they undertake. Cap-and-Trade is not perfectly suited for this issue, but a command-and-control regulation or tax on cattle is not politically possible in Texas, where it is illegal for journalists to take pictures of cow lots[10] and there is a law against defaming beef[11]. No solution to this issue is easy, but it is necessary to find one as the land is only becoming drier and the clouds of dust heavier as droughts increase due to climate change. Cap-and-Trade is the most feasible and efficient solution to provide the people of this region relief. By controlling the amounts of ammonia and small particulates in the air, we can help protect the health of rural citizens across West Texas.


[1] C. Collins, “Something Stinks in West Texas.” in The Texas Observer. (2020, February 13

[2] C. Collins, “Something Stinks in West Texas.” in The Texas Observer. (2020, February 13).

[3] Carrie Hribar, “Understanding Concentrated Animal Feeding Operations and Their Impact on Communities.” National Association of Local Boards of Health. (2010).

[4] Stacy Sneeringer. “Does Animal Feeding Operation Pollution Hurt Public Health? A National Longitudinal Study of Health Externalities Identified by Geographic Shifts in Livestock Production.” In American Journal of Agricultural Economics. (2009).

[5] J. R. Barrett. “Hogging the Air: CAFO Emissions Reach into Schools.” In Environmental Health Perspectives114(4), A241. (2006).

[6] C. Collins, “Something Stinks in West Texas.” in The Texas Observer. (2020, February 13).

[7] C. Collins, “Something Stinks in West Texas.” in The Texas Observer. (2020, February 13).

[8] Wendy Powers, “Environmental Group Petitions EPA to Regulate Ammonia under the Clean Air Act,” MSU Extension, April 26, 2011, https://www.canr.msu.edu/news/environmental_group_petitions_epa_to_regulate_ammonia_under_the_clean_air_a.

[9] “Texas Cattle Feeders Assn Summary | OpenSecrets,” accessed June 24, 2020, https://www.opensecrets.org/pacs/lookup2.php?strID=C00015552.

[10] C. Collins, “It’s Illegal to Take Drone Photos of Feedlots in Texas. Press Groups Say That Violates the First Amendment.” in The Texas Observer. (2020, February 13).

[11] Aman Batheja, “The Time Oprah Winfrey Beefed with the Texas Cattle Industry,” The Texas Tribune, January 10, 2018, https://www.texastribune.org/2018/01/10/time-oprah-winfrey-beefed-texas-cattle-industry/.

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