EPA Greenhouse Gas Ruling Could be Devastating to Agriculture
 
The National Cattlemen's Beef Association (NCBA) is extremely concerned about the potential impacts that the Environmental Protection Agency's (EPA) recent greenhouse gas (GHG) ruling could have on agriculture operations. EPA's decision, announced on Monday, claims that GHG emissions are an endangerment to public health and the environment. This sets the stage for greenhouse regulation under the Clean Air Act (CAA) and would give the EPA unprecedented control over every sector of the U.S. economy.
 
"It's premature to issue this kind of finding, especially given the recent controversy surrounding the scientific validity of alleged human contributions to climate change," said Tamara Thies, NCBA chief environmental counsel.  "Regulation of greenhouse gases should be based on science, and it should be thoughtfully considered and voted on by Congress through a democratic process, not dictated by the EPA."
 
The endangerment finding does not itself regulate GHGs; but unless Congress acts, it sets in motion EPA regulation of GHGs from stationary sources and the setting of new source performance standards for GHGs. On October 27, 2009, EPA proposed a rule designed to regulate GHG emissions from sources that emit 25,000 tons per year or more, instead of the statutory 250 tons per year threshold for pollutants which is included in the Clean Air Act. The extent to which EPA can change statutory permitting requirements, however, is unclear. Only time will tell how our federal courts will address citizen suits to force regulation of all sources that emit GHGs in excess of the statutory thresholds. EPA indicated that it also would be developing an approach to regulate GHGs from hundreds of thousands of small operations, including farms and buildings.
 
While agricultural sources are currently generally not required to obtain permits for greenhouse gas emissions, regulation of GHGs under the CAA may for the first time trigger such regulation. Given the fact that America currently has over 2,000,000 farms, it would be virtually impossible to permit a majority of them. It would also impose massive regulatory compliance costs on producers, which could force many operations out of business.
 
"Congress never intended for the Clean Air Act to be used for greenhouse gas regulation," said Thies. "While the Act has done a good job of cleaning up pollutants, it is not adequately equipped to address global climate change. Any attempts to use it for this purpose would be devastating to U.S. agriculture."
 
According to the EPA, in 2007, GHG emissions from the entire agriculture sector represented less than 6% of total U.S. GHG emissions in Tg CO2 Eq. At the same time, land use, land use change, and forestry activities resulted in a net carbon soil sequestration of approximately 17.4% of total U.S. CO2 emissions, or 14.9% of total U.S. greenhouse gas emissions.
 
"Agriculture actually provides a significant net benefit to the climate change equation," said Thies. "Rather than being subject to overly-burdensome regulations, agriculture should be rewarded for the carbon reductions we provide."
 
NCBA submitted comments in opposition to EPA's proposal in April.

NCBA, PLC Support Safe and Effective Prairie Dog Management Tools
 
The National Cattlemen's Beef Association (NCBA) and Public Lands Council (PLC) submitted comments to the Environmental Protection Agency (EPA) earlier this week in opposition of a petition to suspend the use of prairie dog bait. The bait (Rozol®) is one of the most effective tools among the limited options available for ranchers to balance growing prairie dog populations with the environment and livestock production.
 
The U.S. Fish and Wildlife Service (USFWS) recently concluded that the species does not warrant protection under the Endangered Species Act (ESA). According to USFWS, black-tailed prairie dog habitat has increased from 364,000 acres in 1961 to nearly 2.4 million acres in the most recent data (2002 to 2008).
 
The recent rise in the prairie dog population has created grassland erosion and other natural-resource damage, making the need for effective management tools more important than ever. Studies have shown, when used according to specifications, Rozol is safe and effective, with minimal risk to non-target species and the environment.

 

PLC Works to Support Horse and Burro Management Plan  
 
The Public Lands Council (PLC) and several national environmental groups met with senior Department of Interior (DOI) officials today to discuss the Department's comprehensive approach to curbing horse populations on public lands. The Department's common-sense plan, announced earlier this fall, recognizes both the importance of preserving wild horses and burros and the need to maintain productive, healthy rangeland for multiple uses.

 

The groups share a common interest in preserving our nation's precious natural resources, which have been damaged by the over-population of wild horses and burros. DOI's proposal would create new wild horse preserves in Midwestern and Eastern lands that are not as taxed by drought and wildfire as the western lands currently home to the majority of wild horses. It would also manage population growth of wild horses through fertility control. The adoption process may become more flexible where appropriate, to provide an additional outlet for supporting the animals.