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EPA Should Reevaluate Science Behind Proposed Climate Change Endangerment Finding
 
The National Cattlemen's Beef Association (NCBA) and an informal coalition of companies and trade associations representing U.S. energy and mining sectors submitted comments to the Environmental Protection Agency (EPA) earlier this week regarding a recent EPA proposal to find that human-caused greenhouse gas (GHG) emissions are an endangerment to public health and welfare. The proposed finding, released by EPA in April, is the first step in a process that could require GHG regulation under the Clean Air Act (CAA)-a move that would be devastating to the agriculture sector, and the U.S. economy as a whole.
 
"With so much scientific uncertainty surrounding the question of whether human activity is responsible for climate change, it is inappropriate for the EPA to only consider one side of the debate-especially considering the devastating consequences that their actions could have on an already struggling U.S. economy," says Tamara Thies, NCBA chief environmental counsel. "Additionally, the Clean Air Act is ill-equipped to regulate greenhouse gases. Should EPA move forward, we could find ourselves in a mire of bureaucracy and red tape."   
 
The EPA has said that manure management facilities associated with livestock production account for less than 1% of total U.S. GHG emissions. Regulation of these emissions would be inconsequential to the climate change equation. Rather than being unnecessarily regulated, agriculture should be considered an important solution to climate change.  
 
The comments submitted to the EPA are based upon a number of extensive climate studies conducted by leading environmental scientists from across the world. The following is an excerpt:
 
"...We submit that there is neither a sound nor adequate basis to make a Finding of Endangerment to public health or welfare from anthropogenic greenhouse gases under Section 202(a) of the Clean Air Act. EPA's Proposed Finding fails to acknowledge the profound uncertainty that pervades the current state of scientific knowledge related to human-caused climate change. Instead, the Administrator has touted a supposed 'scientific consensus' while unduly relying on speculative and uncertain data and models, resulting in a Proposed Finding that is nothing more than a tissue of assumptions, presumptions, and unsubstantiated science. Nor has EPA weighed or considered the powerful and substantive scientific evidence from many of the world's scientists calling into question whether climate change is within the range of natural variation or otherwise challenging many of the assumptions on which EPA's proposed finding is based. The Administrator has failed to conduct a balanced, scientifically-based evaluation of the net effects on public health and welfare - positive as well as negative - from warming temperatures. Moreover, regulation of greenhouse gases under the CAA will have severe economic consequences through a regulatory cascade, with no or de minimus net environmental benefit."
 
The groups are urging EPA to postpone regulation until climate science can address the profound uncertainty that currently exists in climate data and modeling.
 
"Before mandating drastic regulation on U.S. industry, EPA has a responsibility to conclusively demonstrate that altering human activities could mitigate climate change issues," Thies says. 
 
For more information, visit: http://www.beefusa.org/NEWSRegulationofGreenhouseGasEmissionsUnder CleanAirActCouldbeDevastatingforUSAgriculture38311.aspx

NCBA Supports Amendments to Protect Producers from Federal Over-Regulation
 
The FY10 Interior-Environmental Protection Agency (EPA) spending bill passed by the House Appropriations Committees last week includes two key amendments supported by the National Cattlemen's Beef Association (NCBA) to protect America's farmers and ranchers from unnecessary and burdensome federal regulation.
 
An amendment by Rep. Latham (R-IA) would prohibit the EPA from requiring cattle operations to report greenhouse gas (GHG) emissions from manure management systems. An amendment by Rep. Tiahrt (KS-R) would prohibit EPA from regulating GHG emissions that result from livestock production under the Clean Air Act (CAA); in other words, it would ensure cattle operations are not subject to a "cow tax."
 
The Senate version of the bill--as passed by the Senate Appropriations Committee earlier today--includes an amendment by Senator Brownback (R-KS) that, like the Tiahrt amendment, would prohibit EPA from regulating GHG emissions from livestock under the CAA. Unfortunately, the Committee failed to pass another Brownback amendment, similar to the Latham amendment, that would have exempted cattle operations from reporting GHG emissions under an EPA registry.
 
Agriculture is a minor source of GHGs overall and should be considered a solution--rather than a contributor--to the climate change problem, by providing important sources of soil carbon sequestration and renewable energy sources and offsets.

Agriculture Appropriations Bill Could Impact U.S.-China Trade
 
In the FY10 Agriculture Appropriations markup last week, the House  Appropriations Committee failed to strip a trade-distorting provision that continues to adversely impact U.S. credibility and potentially hinder U.S. market access overseas. This non-tariff trade barrier was first enacted as Section 727 in the FY08 Agriculture Appropriations bill and again as Section 733 in the FY09 Agriculture Appropriations bill.  As a result of this provision, China has recently filed a World Trade Organization (WTO) challenge regarding this provision.  In addition, this provision is preventing the United States from negotiating an agreement on U.S. beef exports to China, is an impediment to restoring pork exports to China and threatens existing poultry exports to that country.
 
The current provision (Section 723) effectively bans imports of some Chinese chicken products, without allowing USDA's Food Safety and Inspection Service (FSIS) to conduct a necessary and appropriate risk assessment on whether these imports pose any risk to American consumers. Because the provision specifically targets imports from only one country, it conflicts with the U.S. obligation to treat trading partners equally, and prompted the Chinese to seek WTO consultations against the U.S. Most recently, this month, China has moved forward petitioning the WTO for an expert panel review of this issue and investigate the product ban.  
 
The National Cattlemen's Beef Association (NCBA) remains committed to food safety and fair trading practices, and is asking that Senators oppose inclusion of Section 723 in the Senate version of the FY10 Agriculture Appropriations bill.  Striking or replacing Section 723 will not allow cooked poultry products from China entry into the U.S. It will simply allow the experts at FSIS to do their job and make a decision based on sound science as to whether these products should be granted or denied entry-a standard practice employed by all nations in the trading of meat and poultry products. We must adhere to these same standards if we wish to avoid further trade impediments to U.S. agricultural products.
 
If there are concerns about the safety of cooked chicken imports from China, they should be addressed through sound science in the regulatory channels, not through ad hoc legislation or appropriations bills. China represents one of the largest potential growth markets for U.S. beef-worth in excess of $100 million. The chicken dispute is likely to impede ongoing efforts to open up China to U.S. beef.
 
The Senate Appropriations Committee is scheduled to mark up their Agriculture Appropriations bill the week of July 6th. Full House consideration is expected before August recess. 
 

Don't miss NCBA's Cattlemen to Cattlemen!
 
Don't miss NCBA's Cattlemen to Cattlemen, June 30 - July 4. We'll have tips on how to best manage fly problems on your operation this summer and we'll spend a day in the life of a rancher who is a member of the Laguna Pueblo Tribe in New Mexico. We'll also learn more about how segments of the beef industry are working together to promote beef safety. 
 
The show debuts Tuesday at 8:30 p.m. and airs again Wednesday at 10:30 a.m. and Saturday at 9 a.m. (all times are Eastern).  Don't forget, you can watch NCBA's Cattlemen to Cattlemen online anytime by visiting: www.CattlemenToCattlemen.org