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UNITED STATES-CARBON EMISSIONS.

NCBA Expresses Support for Bill to Amend Clean Air Act with Respect to Agriculture Emissions

NCBA sent a letter to Senators Thune and Schumer today expressing support for their bill to amend the Clean Air Act with respect to certain emissions from agricultural production. The bipartisan bill, S. 527, would prohibit the Environmental Protection Agency (EPA) from requiring livestock operations to get Clean Air Act (CAA) Title V permits for greenhouse gas emissions caused by biological processes at those operations.

The CAA is fundamentally ill-suited for regulating Greenhouse Gas Emissions (GHGs), and it was never the intent of Congress for the Act to be used for this purpose. Instead, the Act was intended to regulate traditional air pollutants from major emitters on a state or regional level. While the CAA has seen success in cleaning up criteria and other pollutants, it is not adequately equipped to address global climate change.

Agriculture is a minor source of GHGs overall and should not be regulated under a climate change program. According to the EPA, in 2006, greenhouse gas emissions from the entire agriculture sector represented only 6.4% of total greenhouse gas emissions in teragrams of carbon dioxide equivalents (Tg CO2 Eq) in the U.S. Over half of that amount is due to emissions from soil management when growing crops.

Instead of being subject to climate change regulation, the agriculture sector should be considered an important solution to the climate change problem, as it provides critical sources of soil carbon sequestration and renewable energy offsets. In fact, according to EPA, land use, land use change, and forestry activities resulted in a net carbon sequestration offset of approximately 14.8% of total U.S. CO2 emissions, or 12.5% of total U.S. greenhouse gas emissions in 2006.

Using the CAA in an attempt to control GHG emissions would impose untenable burdens, expenses, and restrictions on industry, families, and our nation as a whole. In addition, such a decision would provide the EPA with unprecedented control over every sector of the U.S. economy. Any decisions to regulate GHGs in the U.S. should be thoroughly and thoughtfully considered by Congress.

Senators Urge FDA to Delay Implementation of Enhanced Feed Ban Rule

Eighteen Senators joined together this week in sending a letter to the Food and Drug Administration (FDA) requesting that the enhanced feed ban implementation date be delayed 60-days and the comment period be re-opened. This would allow affected stakeholders an opportunity to provide more complete information and to comment on the negative impacts already being seen as a direct result of this rule.

"Many in the agriculture industry are concerned that the final rule will be implemented without regard to viable alternatives for safe, economical disposal of deceased livestock," the letter stated. "While the safety of our food supply is the top priority for all of us, we are concerned about the potential for this rule to cause unnecessary economic hardship for farmers and ranchers."

Last month, NCBA joined with 11 other national agriculture organizations in sending a similar letter to FDA. NCBA has opposed the enhanced feed ban rule since the original proposal was published in October 2005 due to its failure to pass a cost/benefit analysis and the lack of statistically valid improvements to animal health and food safety.

Over the past two decades industry and government have worked together to put in place science-based measures which have proven successful in preventing and reducing the spread of BSE in the U.S. International experts agree that a feed ban breaks the cycle of BSE and assures it will be eliminated. The U.S. began our ban of feeding cattle the type of animal-derived protein that can spread BSE in 1997 as a proactive preventative measure. Robust USDA BSE surveillance since 1990 has demonstrated that the firewalls have been successful and the U.S. cattle herd has an extremely low level of risk from BSE.

The very high level of existing U.S. Feed ban compliance combined with an extremely low incidence of BSE suggests that the risk of BSE in the United States is already negligible. This has been proven even more so in the four years since this enhanced feed ban was first proposed and failed an economic cost/benefit analysis.

The final rule on the enhanced feed ban is effective on April 27, 2009. NCBA producers are already suffering negative consequences of this rule months before it goes into effect. Beginning as early as December 2008, many renderers discontinued picking up dead livestock because of the severe economic realities of this proposal. For several months now, NCBA has received numerous reports of producers having difficulty in getting dead animals picked up, and if they are able to find pick-up services, the prices charged by the haulers and renderers is significantly higher than it ever has been.

Many renderers across the country have simply terminated their service to the livestock industry as a direct result of this rule. NCBA and other organizations are hearing from producers and veterinarians across the country that no longer have legal methods to dispose of dead livestock. This affects all species and communities across the U.S., and exacerbates already existing challenges in the proper disposal of livestock carcasses.

NCBA Urges Congress to Protect Private Voting Rights

NCBA joined with more than 40 national and regional agriculture associations earlier this week in sending a letter to Congress urging them to preserve the fundamental right of American workers to a secret ballot election when deciding whether or not to join a union. As a member of the Agriculture for a Democratic Workplace (ADW) coalition, NCBA is working to block the passage of the deceptively named Employee Free Choice Act (EFCA).

The EFCA would effectively deprive American workers-including most agriculture workers-of their right to vote in a private ballot process. Workers would instead be subject to a "card check" program, which would eliminate anonymity and allow for coercion and intimidation during the voting process.

For more information on ADW, visit: www.coalitionforagriculture.org

Comments Requested on Proposed Rule for Animal Identification Numbering Systems

The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (USDA APHIS) is currently accepting comments on a proposed rule regarding official animal identification numbering systems. This rule will directly affect producers, and as such, NCBA recommends that all States and producers submit comments regarding the economic impact this will have on cattle producers.

According to APHIS, the proposed rule, entitled, USDA APHIS "Official Animal Identification Numbering Systems" is the next step in developing a nationally integrated, modern animal disease response system and is intended to create greater standardization and uniformity of official numbering systems and eartags used in both official animal disease programs and the National Animal Identification System (NAIS).

While it would not technically require the use of the animal identification number (AIN), the rule would require that when AINs are used, only those numbers beginning with the 840 prefix will be recognized as official for use. This will be effective for all AIN tags applied to animals one year or more after the date of the finalization of this proposed rule. It would also remove the current Premises Identification Number (PIN) format that uses the State postal abbreviation and proposes to create a single national seven-character alphanumeric code format. Animals that are currently identified with a premise-based numbering system that uses a postal-code PIN would not hav