Ag Airs Concerns

OMAHA (DTN) -- Although U.S. farmers are considered to be relatively small contributors to ozone pollution, a proposal to further tighten federal standards likely would hurt the industry, the American Farm Bureau Federation said in comments submitted to the U.S. Environmental Protection Agency Monday.

In a letter to EPA Administrator Gina McCarthy, AFBF's Executive Director of Public Policy Dale Moore asked the agency to leave in place the current standard of 75 parts per billion for ozone-depleting precursors such as volatile organic compounds, nitrous oxide and others, as part of the National Ambient Air Quality standard. EPA has proposed tightening the standard to between 65 and 70 ppb, drawing concerns across the country in many regions that still have been unable to attain the current standard.

Moore outlined a number of ways agriculture and biofuels could feel the pinch from having to take a number of actions to meet a lower standard.

"Control measures could be implemented that would: curtail production activities; restrict pesticide applications; designate/limit pesticide application times; eliminate pesticide availability; restrict animal agricultural feeding operations due to emissions from animal waste handling and storage; prescribe costly control measures for animal agriculture; and prescribe costly and wasteful control measures for certain food and agricultural processing industries," Moore said.

The ethanol and biodiesel industries could be required to install new technology to reduce volatile organic compounds and nitrous-oxide emissions during biofuel production, he said.

"Agriculture also will be indirectly impacted by costs passed on to the consumer from special requirements for vehicles and fuels (diesel trucks and farm equipment), restrictive permitting requirements that affect plant expansions, and the loss of federal highway and transit funding," Moore said in the letter.

"Farming and ranching are energy-intensive businesses. Farmers and ranchers depend on reliable, affordable sources of energy in their daily operations -- including using tractors and operating dairy barns, poultry houses and irrigation pumps. For farmers and ranchers that compete in a global economy, higher energy costs and fewer transportation options not only hurt competitiveness, but can determine farm viability and prosperity."

Moore said the new standards would "limit business expansion in nearly every populated region of the U.S." and impair the "ability of U.S. companies to create new jobs and agriculture to remain competitive."

"Local communities will face burdens to commercial, industrial and agricultural activity not only vital to creating jobs, but also to providing tax revenue that support local services like public safety and education," he said in the letter.

COSTS, BENEFITS

In announcing the proposed standards last December, EPA estimated the benefits of the regulation "will significantly outweigh the costs." Benefits from preventing risks to health would be between $6.4 billion and $13 billion annually in 2025 for a standard of 70 ppb. Benefits would fall between $19 billion and $38 billion annually in 2025 for a standard of 65 ppb. Annual costs are estimated at $3.9 billion in 2025 for a standard of 70 ppb, and $15 billion for a standard at 65 ppb.

Under the plan, states would be required to offset ozone-forming emissions from new transit or highway projects or projects "undergoing major modifications" by reducing emissions from other existing sources in non-attainment areas.

Ambient air standards have a long history of litigation practically every time EPA proposes a change. Several industries sued after the 2008 revisions, causing EPA to withdraw them, which brought a spate of litigation from groups and states demanding EPA tighten the standards. A 2013 appeals court decision required EPA to factor in an "adequate margin of safety" to protect against uncertain and unknown dangers to public health. Thus, the appeals court told EPA to determine a secondary standard level that protects public welfare.

There has been some legislative effort in Washington to turn back EPA's proposal, including a bill offered by Sen. John Thune, R-S.D., that would block EPA from lowering NAAQ standards for ground-level ozone below 75 ppb until 85% of the current non-attainment counties achieve compliance with the existing standard.

The AFBF questions the need for the stricter standard because of reductions in ozone-depleting emissions since the 1980s.

Todd Neeley can be reached at todd.neeley@dtn.com

Follow Todd on Twitter @toddneeleyDTN

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