Will the EPA Have a Cow?

In response to an April, 2007, Supreme Court ruling that greenhouse gases are air pollutants under the Clean Air Act, the United States Environmental Protection Agency (EPA) recently ended the public comment period on “proposed rulemaking” for regulating greenhouse gases. Buried within the proposal is a controversial measure for regulating methane from agricultural and livestock operations. While EPA bosses claim they do not intend to implement a “cow tax,” dairy and livestock producers are understandably nervous.

Methane is a greenhouse gas, and thus could be among the emissions regulated by the EPA. While the largest sources of methane emissions in the United States are landfills and natural gas systems, the EPA estimates that 21 percent of methane emissions are from “livestock enteric fermentation.” This somewhat euphemistic phrase refers to the natural digestive process of ruminant animals like cows, sheep, and goats, which produces methane as a by-product exhaled by the animal. Production of other types of livestock – pigs, for example – also generates methane through the breakdown of manure products.

Never mind that ruminant animals and their burps are naturally occurring. The proposed regulation could impose a fee on farms with livestock operations that emit more than 100 tons of carbon equivalent per year. This would mean that dairy operations with more than 25 cows, according to the proposal’s calculations, would be subject to regulation. In California the average dairy herd is 850 cows, and only 16 percent of dairies have fewer than 50 cows. At a potential annual fee of $175 per cow, the average California dairy would pay nearly $150,000 per year in greenhouse gas fees. Undoubtedly, this cost would be borne by people who consume dairy products. The story is similar for the proposed fees on cattle and hogs.

Burping cows and other ruminants, however, may not be as critical as originally thought. According to a joint program between the UN’s Food and Agricultural Organization (FAO) and the International Atomic Energy Agency (IAEA), the link between ruminants and atmospheric methane seems to have broken down. Since 1999, atmospheric levels of methane have leveled off, with emissions being equivalent to removals. Yet from 1999 onward, global ruminant populations have been increasing at a rate of almost 17 million head per year, faster than the increase prior to 1999 of about nine million head per year. It may be that improvements in animal husbandry and ruminant diet in developing countries have decrease per-head methane production, or there may be other factors.

Like all agricultural activity, livestock production has environmental impacts. On the other hand, livestock production offers a number of benefits, including a source of renewable fertilizer, and high-quality dietary protein in milk or beef, not to mention the livelihood of 13 million people worldwide. A cow tax would adversely affect those people, and could also wind up a slippery slope. Water vapor accounts for 60-70 percent of the greenhouse effect at any given time. Is it a far stretch to wonder if creatures that exhale water vapor might be next on the fee schedule? Those creatures would include dogs, cats, and human beings.

The idea of regulating cows comes as politicians seek a surge in EPA clout. California Senator Barbara Boxer is pushing to elevate the EPA to presidential cabinet level. Former EPA administrator Christine Todd Whitman is on record that such a move “would deliver a strong message as to the importance of the agency.”

Scientific research, meanwhile, is identifying a number of strategies through which the environmental footprint of livestock production can be decreased while maintaining productivity. Strapping the industry with fees would certainly not promote any of that. Happy cows may come from California, but if a revamped EPA deploys greenhouse gas emission fees, it will create unhappiness for producers and consumers alike, with negligible benefits for the environment.

Nothing contained in this blog is to be construed as necessarily reflecting the views of the Pacific Research Institute or as an attempt to thwart or aid the passage of any legislation.

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