Nebraska Grain and Feed Association
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NGF Objected to Proposed New Regulations, Cheers Retention of Current Standards

Last fall, the Nebraska Grain and Feed Association (NGF) alerted members that the Nebraska Department of Environmental Quality (NDEQ) was considering adopting new modeling methods that could require the inclusion of fugitive dust emissions from truck traffic on haul roads.  NGF reported that the new proposed regulations could cost the grain elevator and processor industry hundreds of thousands of dollars as well new paperwork requirements.  

NGF was notified on March 10, 2010, by the agency that “after careful consideration, NDEQ has decided to retain and continue to follow its March, 2005 policy as it relates to modeling dust."  The decision to retain the 2005 standards is a major victory for Nebraska grain elevators and processing facilities subject to permitting requirements. 

In written comments submitted in September, 2009 opposing the adoption of new dust modeling methods, NGF noted that new internal modeling methods being considered would require additional permit conditions on the PM source adding additional fugitive dust controls or limiting the source of the emissions operations, and that grain elevators in Nebraska could be hit especially hard because most facilities have no buffer between the emission source and the “ambient air boundary” because the plant is located along a public highway or the elevator may not have a practical way to control access to the property.  NGF argued that current NDEQ regulations allowing affected industries the use of “best management practices” (BMPs) as outlined under the 2005 standards to control fugitive dust or particulate matter (PM) on their haul roads was the most practical and affordable approach. 

In the NDEQ letter to NGF, the agency wrote that “feedback received (from stakeholders) indicated that it is premature and unnecessary to make changes to the road dust modeling policy at this time.”  NDEQ went on to state that they will continue to “monitor activity at the national level to study and improve road dust emission factors and the tools used to predict their impact on the ambient air quality.” 

Don’t give regulators an argument in the future for adopting more strict and expensive regulations to control fugitive dust from your haul roads.  We have attached for your review and use the NDEQ letter as well as the March, 2005 Policy Memorandum outlining regulations and identifying best management practices to help control fugitive dust.  Implementing effective and inexpensive BMPs during those days of excessive truck traffic will go a long way to save you and the industry from more unneeded government regulation.  Please print out and prominently post the recommended best management practices contained in the memorandum for you and your employees use.  We would also recommend from time to time documenting the utilization of current BMPs by taking pictures of;


  • Trucks on haul roads with no visible dust generated.
  • Posted speed limit signs.
  • Trucks covered with tarps.
  • Pictures of the above shown on windy days proving that dust on haul roads is not a problem, including the date and a flag showing high winds.
  • Pictures of BMPs including sweepers in use or mineral oil/watering application as effective means to control haul road emissions.




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August 4, 2017

NeGFA Summer Meeting & Golf Outing

York Country Club

York, NE





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Nebraska Grain and Feed Association
4600 Valley Road, Suite 416
Lincoln, NE 68510-4844
Phone: 402-476-6174
Fax: 402-476-3401