The potential impacts of a recent Environmental Protection Agency (EPA) finding that proposes that greenhouse gas (GHG) emissions are an endangerment to public health and welfare, could have a devastating effect on livestock operations, says the National Cattlemen’s Beef Association (NCBA).

The EPA finding is the first step in a process that could require GHG regulation under the Clean Air Act (CAA), and the CAA “is fundamentally ill-suited for GHG regulation,” NCBA says.

“While the Clean Air Act has done a good job of cleaning up pollutants, it’s not adequately equipped to address global climate change,” says Tamara Thies, NCBA chief environmental counsel. “Congress never intended to regulate GHG emissions under the CAA, and any attempts to use it for this purpose would be devastating for the U.S. economy.”

While ag sources are generally not required to obtain permits for greenhouse gas emissions, regulation of GHGs under the CAA may for the first time trigger such regulation. According to the advanced notice of proposed rulemaking for regulating greenhouse gases under the CAA, released last year by the Bush Administration, USDA estimated that “even very small operations would meet the 100 tons/year emissions threshold to require regulation. For example, dairy facilities with over 25 cows, beef cattle operations of over 50 cattle, swine operations with over 200 hogs, and farms with over 500 acres of corn may need to get a Title V permit.”

“Given the fact that America currently has over 2,000,000 farms, it would be virtually impossible to permit a majority of them,” Thies says. “The amount of paperwork, time delays and new technology needs would be insurmountable. In addition, most of America’s agricultural producers simply would not be able to afford the regulatory compliance costs that would be imposed on them under such a program, and they would be forced out of business.”

NCBA says that, according to the EPA, in 2006, GHG emissions from the entire ag sector represented only 6.4% of total U.S. GHG emissions in Tg CO2 Eq. (Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006, U.S. Environmental Protection Agency, April 15, 2008). At the same time, land use, land use change and forestry activities resulted in a net carbon soil sequestration of approximately 14.8% of total U.S. CO2 emissions, or 12.5% of total U.S. greenhouse gas emissions. This means that agriculture provides a significant net benefit to the climate change equation.

“Rather than being subject to overly burdensome regulations, agriculture should be considered part of the solution to the climate change issue,” Thies says. “Agricultural operations can serve as an important source of carbon offsets to enable regulated industries to comply with any cap set by climate change legislation.”

NCBA plans to submit comments to EPA during the upcoming 60-day public comment period.
-- NCBA release