Hanta Yo
Well-known member
NCBA has been receiving a number of questions recently regarding a Farm
Bureau Letter that gives the impression that the EPA plans to regulate
greenhouse gases (GHGs) under the Clean Air Act and that this would mean
producers would have to pay what AFBF estimates to be an $87.50 "tax" per
head to comply.
NCBA was asked to sign on to the letter and we declined since there is no
proposal to regulate GHGs under the Clean Air Act (CAA) and we believe the
letter unnecessarily stirs up fear among producers in this extremely
volatile cattle and beef market.
The letter also makes it sound like the livestock industry is a large
emitter of GHGs, when EPA data shows that it is not. In addition, it is
hard to imagine that the Obama Administration would allow GHGs to be
regulated under the CAA because the consequences of doing so would be
devastating to our entire economy.
While the content of the letter may be technically correct if the worst case
scenario were to happen, only the most radical environmental groups believe
it is appropriate to regulate GHGs under the Clean Air Act. EPA
Administrator Steve Johnson wrote in the Advanced Notice of Proposed
Rulemaking (ANPR) seeking public comment on such regulation that the Clean
Air Act is "an outdated law . . . ill-suited for the task of regulating
global greenhouse gases." One of the purposes of the ANPR was to make the
public aware of the economic devastation that would be imposed on this
country if GHGs were regulated under the CAA. But no one has formally
proposed to do so.
While it is unfortunate that one of President-elect Obama's senior staff
recently threatened to regulate GHGs under the CAA if Congress does not pass
climate change legislation within 18 months of Obama taking office, it is
simply being used as a threat instead of a real proposal. It would be
irrational for the Obama Administration to allow the resulting economic
devastation to occur. That is why Congress has debated climate change
legislation that would establish a more appropriate cap-and-trade program to
control GHG emissions instead of allowing them to be regulated under current
CAA programs. Legislators are expected to continue this debate in the new
Congress, and are likely to pass climate change cap and trade legislation
within the next several years.
While it is impossible to predict the future, climate change bills to date
have generally considered agriculture to be a solution to climate change
issues, instead of one of the problems. Since the agriculture industry as a
whole is a relatively minor emitter of GHGs (6.4% of the total), our
industry could be used to provide offsets to regulated industry. Cattle
operations could provide such offsets by sequestrating carbon in soils on
rangelands, croplands and pasturelands, and possible combustion of manure to
create alternative energy sources, among other options. An agriculture
offset program would enable regulated industries such as the utility,
automobile, and manufacturing sectors to comply with any cap that Congress
may set. Regulated industry would purchase offsets from agriculture to meet
their obligations under a cap. This legislative outcome is much more likely
to occur than is regulation of GHGs under the CAA.
The "worst case scenario" for NCBA members is that some of our largest
producers may be brought under a "catch-all" cap that may be included in a
final legislative package. This may happen if a final package contains
language that states, for example, that "any entity in the U.S. that emits
10,000 tons (or 25,000 tons) of CO2 equivalent GHGs fall under the cap." If
this were to happen, emissions from cattle producers who meet this threshold
would have to be decreased to a level at or below a cap, or they may
purchase offsets to comply.
NCBA continues to work on this issue to protect the interests of cattle
producers.
Bureau Letter that gives the impression that the EPA plans to regulate
greenhouse gases (GHGs) under the Clean Air Act and that this would mean
producers would have to pay what AFBF estimates to be an $87.50 "tax" per
head to comply.
NCBA was asked to sign on to the letter and we declined since there is no
proposal to regulate GHGs under the Clean Air Act (CAA) and we believe the
letter unnecessarily stirs up fear among producers in this extremely
volatile cattle and beef market.
The letter also makes it sound like the livestock industry is a large
emitter of GHGs, when EPA data shows that it is not. In addition, it is
hard to imagine that the Obama Administration would allow GHGs to be
regulated under the CAA because the consequences of doing so would be
devastating to our entire economy.
While the content of the letter may be technically correct if the worst case
scenario were to happen, only the most radical environmental groups believe
it is appropriate to regulate GHGs under the Clean Air Act. EPA
Administrator Steve Johnson wrote in the Advanced Notice of Proposed
Rulemaking (ANPR) seeking public comment on such regulation that the Clean
Air Act is "an outdated law . . . ill-suited for the task of regulating
global greenhouse gases." One of the purposes of the ANPR was to make the
public aware of the economic devastation that would be imposed on this
country if GHGs were regulated under the CAA. But no one has formally
proposed to do so.
While it is unfortunate that one of President-elect Obama's senior staff
recently threatened to regulate GHGs under the CAA if Congress does not pass
climate change legislation within 18 months of Obama taking office, it is
simply being used as a threat instead of a real proposal. It would be
irrational for the Obama Administration to allow the resulting economic
devastation to occur. That is why Congress has debated climate change
legislation that would establish a more appropriate cap-and-trade program to
control GHG emissions instead of allowing them to be regulated under current
CAA programs. Legislators are expected to continue this debate in the new
Congress, and are likely to pass climate change cap and trade legislation
within the next several years.
While it is impossible to predict the future, climate change bills to date
have generally considered agriculture to be a solution to climate change
issues, instead of one of the problems. Since the agriculture industry as a
whole is a relatively minor emitter of GHGs (6.4% of the total), our
industry could be used to provide offsets to regulated industry. Cattle
operations could provide such offsets by sequestrating carbon in soils on
rangelands, croplands and pasturelands, and possible combustion of manure to
create alternative energy sources, among other options. An agriculture
offset program would enable regulated industries such as the utility,
automobile, and manufacturing sectors to comply with any cap that Congress
may set. Regulated industry would purchase offsets from agriculture to meet
their obligations under a cap. This legislative outcome is much more likely
to occur than is regulation of GHGs under the CAA.
The "worst case scenario" for NCBA members is that some of our largest
producers may be brought under a "catch-all" cap that may be included in a
final legislative package. This may happen if a final package contains
language that states, for example, that "any entity in the U.S. that emits
10,000 tons (or 25,000 tons) of CO2 equivalent GHGs fall under the cap." If
this were to happen, emissions from cattle producers who meet this threshold
would have to be decreased to a level at or below a cap, or they may
purchase offsets to comply.
NCBA continues to work on this issue to protect the interests of cattle
producers.