The Environmental Protection Agency’s proposal to regulate greenhouse gases under the Clean Air Act could wind up being essentially a new tax on agricultural operations in Kansas and across this country. 

   What's the story?

   The EPA wants to regulate automobile emissions, but they first have to make a finding that greenhouse gases endanger public health and safety and should be classified as a “pollutant.” 

   “Greenhouse gases” are those alleged to contribute to global warming.  The major greenhouse gases are carbon dioxide, methane and nitrous oxides, while hydroflorocarbons comprise a smaller amount. 

   The problem under this plan?

   Most livestock and dairy farmers would be impacted immediately and would not be able to pass along the costs incurred. Steep fees associated with this action would force many producers out of business. The net result would likely be higher consumer costs for milk, beef and pork.

   According to Agriculture Department figures, any farm or ranch with more than 25 dairy cows, 50 beef cattle or 200 hogs emits more than 100 tons of carbon equivalent each year. More than 90 percent of U.S. dairy, beef and pork production would be affected under the EPA proposed rules.

   Permit fees vary from state to state but EPA sets a presumptive minimum rate for fees. For 2008-2009, the rate is $43.75 per ton of emitted greenhouse gases. This proposed fee would mean annual assessments of $175 for each dairy cow, $87.50 for each head of beef cattle and $20 for each hog.

   But it isn’t just livestock producers who face the uncertainty of these proposed regulations. Increased costs in fuel, fertilizer and transportation are also likely to occur if these regulations are put in place.

   Agriculture is no different than any other industry in that it is susceptible to potential economic and social changes. However it is vastly different than most other industries because it has little or no ability to pass increased costs of doing business to consumers.

  “Agriculture profitability is dependent on today’s global markets that are controlled by individuals and entities completely outside of agriculture,” says Ottawa County producer Steve Baccus. “With this understanding, we are concerned about the proposed rulemaking and its potential negative impact on an industry that consistently struggles to stay financially stable in a highly volatile world market.”

   Baccus who also serves as Kansas Farm Bureau president made these comments on behalf of more than 40,000 farmers and ranchers in a letter to EPA Administrator Stephen Johnson.

   “The EPA is getting ahead of its headlights,” Baccus says. “If the feds feel compelled to regulate greenhouse gases from sources other than combustion engines, they should provide a new regulatory framework and rules first.”

   Baccus is referring to the ruling in Massachusetts vs. EPA, which specifically addresses tailpipe emissions from new vehicles, but EPA has considered this as a potential launching pad for regulations pertaining to several other mobile and stationary sources of greenhouse gases.

   The proposed rules would be ineffective because of the global nature of greenhouse gases. Reducing a ton of greenhouse gases anywhere will make a difference, but if a ton is removed in Kansas and replaced by a ton in China, then no net effect occurred.

   An agricultural tax and regulation of greenhouse gases under the Clean Air Act will impose restrictions and added costs on the U.S. economy without reducing greenhouse gases in the atmosphere, if the rest of the world doesn’t have to play by the same rules. 

   Another aspect of the EPA proposal that is discussed briefly, but really doesn’t acknowledge the full breadth in the notice is the positive impact agriculture may have on greenhouse gas emissions.

   No-till farming practices, methane capture and rangeland/grass management has the potential to store millions of tons of carbon annually. Given the right market-driven or voluntary, incentive-driven environment, agriculture could hold at bay the increases in greenhouse gas emissions to the atmosphere while technology is developed and made more affordable to reduce or prevent releases from industry.