farmgate: Is EPA's "Cow Tax" Real Or Just A Good Rumor?
We’ve all heard the coffee shop rumors that EPA will impose a cow gas tax on every livestock producer to reverse global warming. That is great fodder to chew, but what are the real proposals, what would they do, and who would be affected? Once those issues are clear, agriculture can make an appropriate response.
The issue involves greenhouse gases, abbreviated as GHG, and there are many, but for the purposes of livestock producers, the major ones are carbon dioxide and methane. Agricultural and Biological Engineers Ted Funk and Randy Fonner at the University of Illinois offer their analysis, saying the US EPA proposes a reporting requirement of facilities with manure management systems that have annual emissions exceeding 25,000 metric tons of carbon dioxide equivalent. Funk and Fonner say, “No other GHG emission source associated with agriculture is proposed to be covered.” Frankly, few farmers have the knowledge and equipment to have calculated GHG emissions at their facility. Funk and Fonner say EPA’s method of calculations indicates, “that 40 to 50 of the largest livestock facilities would be required to report at the 25,000 mtCO2e per year threshold level.”
If you are not managing one of the 40 to 50 largest livestock facilities, you probably are going to quit reading and think it does not concern you. However, this issue is like any dairy herd, and once the gate is open, the other cows will follow the leader through the open gate. In other words, all livestock producers may want to become familiar with the issue, since there may be subsequent regulations that would impact their operation.
Funk and Fonner believe the EPA regulations stopped where they do because of the challenges to estimate GHG emissions. They say measurements with current technology produce uncertain results at smaller facilities. At this point, the only gas being measured for reporting requirement is carbon dioxide; and methane produced in the digestive process is not included. That will upset some of the late night TV comedians.
According to the proposed EPA rule, the reporting requirement is applied to a “manure management system or facility.” Funk and Fonner list those as:
· Digesters
· Storage pits
· Liquid/slurry systems
· Uncovered anaerobic lagoons
· Feedlots and other drylots
· Manure composting
· Solid manure storage
· Other poultry production with litter
· High-rise houses for poultry production
· Deep bedding systems for cattle and swine
Such facilities include “physical property, plant, building, structure, source, or stationary equipment. Even if an access lane or even a township road separates them, the issue is who controls it and does it emit any GHG.
If you have no livestock, you are exempt from the reporting requirement. So if you are burning off crop residue, composting, or raising row crops you are not covered by the rule. If you have a large incinerator for some reason on your farm, and produce more than 25,000 metric tons of carbon dioxide equivalent per year, you would have to fill out the require paperwork. Funk and Fonner compare that level of emission to 2,200 homes, or burning either 58,000 barrels of oil or 131 railcars of coal.
So if you are one of those that have to comply with the reporting requirement, what has to be done in addition to paperwork? Funk and Fonner say there are no taxes or fees proposed at this time. Anyone uncertain if they are producing more than 25,000 metric tons of carbon dioxide per year is required to obtain the measuring equipment and determine if they must comply, which would cost about $900 per facility. The ag engineers also indicate there are ways of estimating, based on calculations that the EPA can provide, before having to spend the money. Data collection would begin next January, and the annual report would be due in March of 2011.
Summary:
Proposed regulations by the EPA would impact the largest 40 to 50 livestock operations by requiring them to annually report emissions of more than 25,000 metric tons of carbon dioxide. Taxes and fees are not proposed, however there would be a cost of data collection. Smaller livestock facilities and crop agriculture are not included in the reporting requirement. The specific point of carbon dioxide emissions would be manure management facilities, not individual animals.
Posted by Stu Ellis on April 27, 2009 12:56 AM to farmgate