reasons. However, with the appropriate data identified there may be viable alternatives to the currently proposed approach.

Finding 8: A process-based model farm approach that incorporates “mass balance” constraints for some of the emitted substances of concern, in conjunction with estimated emission factors for other substances, may be a useful alternative to the model farm construct defined by EPA (2001a). The committee plans to explore issues associated with these two approaches more fully in its final report.

Discussion: The mass balance approach, like EPA’s model farm approach, starts with defining feeding operations in terms of major stages or activities. However, it focuses on those activities that determine the movement of nutrients and other substances into, through, and out of the system. Experimental data and mathematical modeling are used to simulate the system and the movement of reactants and products through each component of the farm enterprise. In this approach, emissions of elements (such as nitrogen) cannot exceed their flows into the system.



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