The Environmental Protection Agency has issued an advance notice of proposed rulemaking seeking public comment on whether it is appropriate to regulate greenhouse gas (GHG) emissions from automobiles under the Clean Air Act.
This may sound like a good idea. But, in order to regulate automobile emissions, the EPA would first have to make a finding that greenhouse gases endanger public health and safety and should be classified as a "pollutant."
Therein lies the problem for agriculture.
Once the endangerment finding is made, other provisions of the Clean Air Act are automatically triggered, creating much broader regulation of other sectors of the economy, including agriculture. One consequence would be a cow and pig tax.
That's because if an endangerment finding is made, Title V of the Clean Air Act is triggered. Title V requires that any entity emitting more than 100 tons per year of a regulated pollutant must obtain a permit in order to continue to operate. EPA has no choice but to require these permits once an endangerment finding is made.
USDA has stated that any operation with more than 25 dairy cows, 50 beef cattle or 200 hogs emits more than 100 tons of carbon and would have to obtain permits under Title V in order to continue to operate if GHG are regulated. According to USDA statistics, this would cover about 99 percent of dairy production, over 90 percent of beef production and over 95 percent of all hog production in the United States.
The amounts of the tax can vary from state to state. The EPA has a "presumptive minimum rate" for Title V permits of $43.75 for this year. If a state charged this rate, the cow tax for dairy would be $175 per cow, for beef cattle $87.50 per head, and a little more than $20 per pig.
EPA has requested public comments on this advance notice. Comments are due by Friday, Nov. 28.
Send comments to:
Air and Radiation Docket and Information Center
Environmental Protection Agency, Mail code: 2822T
1200 Pennsylvania Ave., NW.
Washington, DC 20460.
RE: Docket ID No. EPA-HQ-OAR-2008-0318
In addition, write or call your Congressional delegation and tell them to prevent the imposition of a cow tax and a pig tax that would occur by the regulation of greenhouse gases through the Clean Air Act
Source: Oregon Department of Agriculture and the American Farm Bureau Federation
This may sound like a good idea. But, in order to regulate automobile emissions, the EPA would first have to make a finding that greenhouse gases endanger public health and safety and should be classified as a "pollutant."
Therein lies the problem for agriculture.
Once the endangerment finding is made, other provisions of the Clean Air Act are automatically triggered, creating much broader regulation of other sectors of the economy, including agriculture. One consequence would be a cow and pig tax.
That's because if an endangerment finding is made, Title V of the Clean Air Act is triggered. Title V requires that any entity emitting more than 100 tons per year of a regulated pollutant must obtain a permit in order to continue to operate. EPA has no choice but to require these permits once an endangerment finding is made.
USDA has stated that any operation with more than 25 dairy cows, 50 beef cattle or 200 hogs emits more than 100 tons of carbon and would have to obtain permits under Title V in order to continue to operate if GHG are regulated. According to USDA statistics, this would cover about 99 percent of dairy production, over 90 percent of beef production and over 95 percent of all hog production in the United States.
The amounts of the tax can vary from state to state. The EPA has a "presumptive minimum rate" for Title V permits of $43.75 for this year. If a state charged this rate, the cow tax for dairy would be $175 per cow, for beef cattle $87.50 per head, and a little more than $20 per pig.
EPA has requested public comments on this advance notice. Comments are due by Friday, Nov. 28.
Send comments to:
Air and Radiation Docket and Information Center
Environmental Protection Agency, Mail code: 2822T
1200 Pennsylvania Ave., NW.
Washington, DC 20460.
RE: Docket ID No. EPA-HQ-OAR-2008-0318
In addition, write or call your Congressional delegation and tell them to prevent the imposition of a cow tax and a pig tax that would occur by the regulation of greenhouse gases through the Clean Air Act
Source: Oregon Department of Agriculture and the American Farm Bureau Federation