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Letter to The Honorable Stephen L. Johnson, Administrator, United States Environmental Protection Agency

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Location: Washington, DC


Letter to The Honorable Stephen L. Johnson, Administrator, United States Environmental Protection Agency

Shelby Opposes EPA Proposed Greenhouse Gas Regulations

U.S. Senator Richard Shelby (R-Ala.) today sent a letter to U.S. Environmental Protection Agency (EPA) Administrator Stephen Johnson to urge the Agency to reexamine a proposed rule to regulate greenhouse gas emissions under the Clean Air Act. The proposed rule would adversely affect livestock producers throughout Alabama and the nation.

"Agriculture is Alabama's largest industry and it is critical that the EPA consider the economic and regulatory impact that any proposed rule aimed at the agriculture industry will have on our state's producers," said Shelby. "Unfortunately, the EPA's proposed approach to regulate natural agriculture emissions does not account for the significant costs, burdens, and adverse consequences on the agriculture industry in Alabama and throughout the nation. For this reason, I urge the EPA to reexamine the approach outlined in its proposal."

Under the EPA's proposed rule, farming operations that produce more than 100-tons-per-year of naturally occurring agriculture emissions would be subject to the costly, burdensome Clean Air Act's Title V permitting process.

Full text of the letter is below.

December 1, 2008

The Honorable Stephen L. Johnson
Administrator
United States Environmental Protection Agency
1200 Pennsylvania Ave, NW
Washington, DC 20460

RE: EPA-HQ-OAR-2008-0318

Dear Administrator Johnson,

I am writing to express concern regarding the unintended consequences of the approach proposed by the Environmental Protection Agency's (EPA) Advance Notice of Proposed Rulemaking "Regulating Greenhouse Gas Emissions under the Clean Air Act." Specifically, I am troubled by the potential impact on the agriculture industry in Alabama and throughout the nation.

Using the Clean Air Act (CAA) to address climate change would likely have significant economic consequences for the agriculture industry. The U.S. Department of Agriculture clearly stated the impact of this proposed rule in the Federal Register:

If GHG emissions from agricultural sources are regulated under the CAA, numerous farming operations that currently are not subject to the costly and time-consuming Title V permitting process would, for the first time, become covered entities. Even very small agricultural operations would meet a 100-tons-per-year emissions threshold. 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. It is neither efficient nor practical to require permitting and reporting of GHG emissions from farms of this size. Excluding only the 200,000 largest commercial farms, our agricultural landscape is comprised of 1.9 million farms with an average value of production of $25,589 on 271 acres. These operations simply could not bear the regulatory compliance costs that would be involved.

The agriculture industry is Alabama's largest, accounting for 21 percent of Alabama's workforce. The impact of EPA's actions in this area would be devastating to Alabama's agribusiness and would hit our state's smallest farmers the hardest. If applied to small farmers, many of the CAA's emissions regulations would require agricultural producers to control emissions only through limiting production, likely forcing smaller farmers to cease farming altogether. The draft proposal does not account for the significant costs, burdens, and adverse consequences the agriculture industry would face under the regulation of greenhouse gas emissions through the CAA. I believe the results could be catastrophic for the nation's farmers

While EPA's desire to address greenhouse gas emissions is clear, doing so by bankrupting our nation's farmers far outweighs any potential environmental benefit from this regulation. Therefore, I urge the Agency to reexamine the approach outlined in this proposal. The livelihood of hundreds of thousands of Alabama agriculture workers, and millions of workers nationwide, depend upon it.

Sincerely,

Richard Shelby


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