Ag groups ask Congress to address GHG emissions from annual crops
The Biogenic CO2 Coalition sent a letter to Capitol Hill on May 11 asking lawmakers to direct the U.S. EPA to promptly publish a rule that states neither agricultural biomass nor woody biomass contribute to excess greenhouse gases (GHGs) in the atmosphere.
“For over 10 years the Biogenic CO2 Coalition, representing farmers and agricultural crop processors, has urged the [EPA] to promulgate a rule clarifying that natural (i.e., biogenic) carbon dioxide from the processing or use of agricultural crops is not harmful pollution because it was captured within the previous year when crops were grown,” the group wrote. “Therefore, biogenic CO2 should not be regulate the same as fossil-fuel emissions under the Clean Air Act. We respectfully request that you seek assurances of a prompt publication of a rule proposing de minimis characterization of biogenic CO2 from annual crops. For years, we have been advised that EPA plans to address this problem.”
The letter references a proposed rule the EPA recently submitted to the White House Office of Management and Budget for review. “Astoundingly, we have learned that this draft rule does not address biogenic CO2 from annual crops (one year life cycle), instead only proposing carbon neutrality for emissions from wood biomass (forty year life cycle),” the coalition wrote. “Recently, a senior EPA official admitted to our coalition chair that EPA has no meaningful plan to address biogenic CO2 from annual crops.”
The letter notes that the EPA lacks the scientific evidence necessary to regulate biogenic CO2 as a harmful pollutant, that the agency is the only national regulatory authority in the world to regulate biogenic CO2 on the same basis as fossil fuel-base emissions, that EPA’s own GHG inventory recognizes annual crops as a carbon sink, and that the regulatory burden associated with the EPA’s biogenic CO2 policy is thwarting development of the bioeconomy and creating a market advantage that favors foreign competitors.
While the coalition says said it supports EPA’s effort to clarify the regulatory status of wood biomass, it objects to EPA’s failure to address biogenic emissions from agricultural feedstocks. “When regulating emissions under the Clean Air Act, EPA should acknowledge the science of carbon cycles and regulate only emissions that actually add excess greenhouse gases to the atmosphere. In the case of agricultural crops, carbon emitted in the processing of corn, cotton, soybean or other oilseeds was captured only the year before and is immediately captured again during the next year’s planting,” the coalition wrote. “Extensive scientific literature and positions of government agencies, including the U.S. Department of Agriculture, agree that biogenic emissions from crop-based feedstocks are carbon neutral, de minimis or insignificant from a carbon accounting and regulatory perspective. There is no scientific or practical reason for EPA to ignore the life cycle of annual crops.”
The coalition notes that America’s bioeconomy currently contributes $393 billion in economic activity, provides 4.3 million American jobs, and is the leading source of domestic renewable energy in the U.S. “Building on the success of pioneering biotechnology, our coalition members are poised to invest billions of dollars in rural America,” the coalition continued. “Without regulatory relief, that significant opportunity for rural America’s economic development will be missed and American farmers will face even greater competition from overseas.”
The coalition notes its members have met with and written to EPA on this issues many times over the years. The primary reason we have been given for EPA advancing a rule to address biogenic CO2 from woody biomass, but not from annual crops, is Congressional direction in the form of an appropriations rider,” the coalition wrote. “As EPA is not moving into alignment with science regarding biogenic CO2 from annual crops, but at least responding to Congressional directives, we respectfully urge your efforts to provide EPA the Congressional input that it apparently needs to recognize the biogenic CO2 from annual crops is de minimis.”
Members of the Biogenic CO2 Coalition include the American Farm Bureau Federation, Corn Refiners Association, National Corn Growers Association, National Cotton Council of America, National Cottonseed Products Association, National Oilseed Processors Association, North American Millers’ Association, and Plant Based Products Council.
A full copy of the letter can be downloaded from the CRA website.