The Honorable Tom Vilsack
US Department of Agriculture
1400 Independence Ave., S.W.
Washington, D.C. 20010
The Honorable Ernest Moniz
US Department of Energy
100 Independence Ave., S.W.
Washington, D.C. 20585
The Honorable Gina McCarthy
US Environmental Protection Agency
1200 Pennsylvania Ave., N.W.
Washington, D.C. 20460
Dear Secretary Vilsack, Secretary Moniz, and Administrator McCarthy:
We are writing today in regards to the president's plan released on March 28, 2014, to reduce methane emissions. In particular, we are concerned about potential actions against the agriculture community to regulate methane and other greenhouse gas (GHG) emissions, which could severely impact the livestock industry.
The president's Climate Action Plan "Strategy to Reduce Methane Emissions" targeted a number of industries for methane emission reductions, including agriculture. Specifically the plan calls on the U.S. Department of Agriculture (USDA), Environmental Protection Agency (EPA), and Department of Energy (DOE) to outline a "Biogas Roadmap" to reduce dairy sector GHG emissions by 25 percent by 2020 through voluntary strategies.
Federal regulations of GHGs in the agriculture sector would have detrimental implications on livestock operations across the country. In 2008, as part of its Advanced Notice of Proposed Rulemaking to regulate GHGs under the Clean Air Act, the EPA deliberated regulating agriculture-related emissions, which would have required farmers to purchase expensive permits. It was estimated that these top-down regulations would have cost medium-sized dairy farms with 75 to 125 cows between $13,000 and $22,000 a year, and medium-sized cattle farms with 200 to 300 cows between $17,000 and $27,000. We reject the notion that the EPA should, absent express authorization from Congress, seek to regulate the agriculture sector in this manner.
The agriculture community is committed to environmental stewardship, which is evidenced by the 11 percent reduction in agriculture-related methane emissions since 1990. It is our hope that the EPA, USDA, and DOE will work with Congress and the agriculture industry to outline voluntary measures that can be taken to reduce emissions without imposing heavy-handed regulations on farms across America. We respectfully request that you commit in writing to refrain from proposing new regulations, guidelines, or other mandatory requirements on methane or other GHGs from the agriculture industry.
Thank you for your consideration and attention to this matter.