T he FCAA signed by President Bush in 1990 has impacted the process used by SAPRAs in regulating air pollution attributed to grain handling facilities including feed mills associated with cattle feed yards. The most significant impact of the FCAA Amendments of 1990 is the establishment of the Title V operating permit program (Novello, 1991). The Title V operating permit program requires that all sources of air pollution designated as major sources will be required to pay Title V annual emission fees and obtain a Federal Operating Permit (FOP). The FCAA Amendments of 1990 will have serious implications for many types of industries, including agriculture (Lesikar et al., 1996; Parnell, 1994; Wallin et al.). Major sources in attainment areas are those emitting more than 91 tonnes (100 tons) of a regulated pollutant per year. In non-attainment areas, facilities emitting less than 91 tonnes (100 tons) of a regulated pollutant may be designated a major source. EPA has established that the annual emission rate of particulate matter less than or equal to 10 microns (PM10) would be used to determine if a grain elevator or feed mill would be a major source (Wegman, 1995). The annual emission rate and Title V emission fee for a pollution source is calculated using AP-42 emission factors published by EPA. AP-42 emission factors are also used by SAPRAs in determining the maximum AER. Hence, there is a need to be as accurate as possible in establishing emission factors for any emitting source. The definition of air pollution can be stated as: ".. . the presence in the outdoor atmosphere of any one or more substances or pollutants in quantities which are or may be harmful or injurious to human health or welfare, animal or plant life, or unreasonably interfere with the enjoyment of life or property, including outdoor recreation," (Cooper and Alley, 1994). The role of air pollution regulations is to protect the public (off site). Regulating air pollution includes three functions: (1) formulation of rules, regulations, and standards which establishes the criteria for enforcement; (2) "permitting" which establishes the controls required for a facility to be in compliance with the rules and regulations; and (3) enforcement which establishes the types of punishment for violators. Enforcement is dependent upon rules, regulations, and permitting. If the rules and regulations (in this case, emission factors) are inaccurate for a particular industry, it will not be possible for SAPRAs to properly regulate emissions attributed to that industry. The AP-42 emission factors (EPA, 1988) for grain elevators and feed mills published by the EPA in 1988 were not correct (Parnell et al., 1994). The EPA recognized the errors and published interim factors for country elevators/feed mills (EPA,1995). The major changes were to reduce the emission factors associated with handling, hammer milling, flaking, cracking, and pellet cooling to zero, while calculating the total emission factor: "For smaller animal feed mills located at cattle feedlots, the mos...