Related Documents Environmental Protection Agency

Washington, June 10, 2009  -

The U.S. Environmental Protection Agency’s proposal to require livestock agriculture to report manure-related greenhouse gas emissions is not well thought out and could increase environmental problems, according to the National Pork Producers Council.

In comments on the plan submitted yesterday, NPPC applauded EPA’s efforts to address global climate change and provide leadership in protecting the environment. But the group said requiring livestock producers to report manure-related emissions will add costs to pork operations while basically duplicating information EPA already compiles. The group said EPA should step back and let the Agriculture Department take the lead in attempting to reduce greenhouse gases coming from farms and ranches.

“The current greenhouse gas inventory that EPA compiles every year, along with the information from a cap and trade offsets program, is more than enough to support the rule’s objectives,” NPPC said. “Its proposal simply adds great costs to the covered producers without adding anything to the current body of knowledge regarding manure emissions.”

Congress is considering climate change legislation that, among other things, would set a limit, or cap, on the amount of greenhouse gases that specific large emitters such as energy utilities could release to the atmosphere. Each unit of greenhouse gas an emitter is allowed to release under its cap is called a credit, which may be bought and sold. Those able to release less gas than they are allowed under their cap may sell credits; those over it will need to buy credits or reduce their energy production.

In March, EPA proposed to require businesses, including livestock operations, to report emissions of carbon dioxide, methane and nitrous oxide under the Clean Air Act. Those emitting at least 25,000 metric tons of gas annually would be affected under the plan. EPA estimated this would be only 40 to 50 livestock operations nationwide and that compliance costs would be only $900 per facility.

Minnesota hog farmer Randy Spronk, chairman of NPPC’s environmental committee, questioned EPA’s reporting threshold, saying the agency misjudged the number of producers the rule would affect and the costs it would impose.

The pork industry, Spronk pointed out, is participating in an EPA air monitoring study that will determine with much more certainty the greenhouse gases coming from hog farms, but that data won’t be available until next year. “Until we know what’s coming off our farms and in what amounts, producers should be protected from regulation for air emissions,” he said.

In its comments, NPPC offered a number of reasons why EPA’s mandatory emissions reporting program is not appropriate for hog farms and needs to be revised. Among them: 

  - Relying on the Clean Air Act to address climate change will steer pork producers toward   actions that will increase emissions and could cause additional environmental problems.   Additional reporting requirements, for example, are a disincentive to installing manure   lagoon covers and manure digesters that can capture methane gas and convert it to   electricity.

  - The Agriculture Department is better equipped than EPA to administer a greenhouse gas   program for livestock producers. It has the technical expertise and institutional   resources, along with a track record for working with farmers on measuring reductions in   greenhouse gas emissions. Also, USDA has the producer protections required to assure   widespread participation in any greenhouse gas reduction program.

  - EPA’s proposal exempts from reporting requirements greenhouse gas emissions from natural   processes such as from animals’ digestive systems. But it doesn’t exempt manure   decomposition—also a natural process—even though it accounts for only a small portion of   total livestock-related greenhouse gas emissions.

  - EPA failed to adequate describe which operations are subject to mandatory reporting.   Conflicting definitions of “facilities” and “manure management systems” leave in doubt who   is covered under the regulation and who is not.

  - While EPA estimated that farms with at least 73,000 hogs will be required to report   emissions, it did not explain how it arrived at this number. NPPC, working with industry   and university scientists, has been unable to duplicate it.

  - The costs of the recordkeeping and reporting requirements under the rule are   underestimated. EPA’s estimate of $900 to conduct tests and do emissions calculations   bears little relation to the actual costs hog farmers will incur to comply with the rule. 
 

[To read NPPC’s comments, visit www.nppc.org and go to “Newsroom,” “Testimony/Comments.”]

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