USEPA has released a draft version of a greenhouse gas monitoring program for public comment. The rule would require a wide range of industrial sources of greenhouse gases to report their annual contribution to USEPA.
Most farmers will not be directly affected by this greenhouse gas monitoring program. The monitoring rule excludes greenhouse emissions from agricultural activities such as tillage and burning residue on crop fields. It also excludes agricultural sources such as composting not associated with confined animal feeding operations and emissions from agricultural soils.
A preliminary version of this rule had suggested what had been dubbed a "cow tax" on cows and other ruminant animals for methane released during digestion. The proposed rule specifically excludes methane directly released by ruminant animals from monitoring requirements.
The one agricultural greenhouse gas source specifically targeted by the greenhouse monitoring rule is losses of methane and nitrous oxide from manure storage facilities. The proposed rule requires operations with manure storage facilities that emit more than 25,000 metric tons of carbon dioxide equivalents to report under the terms of the rule. An initial assessment of the rule implies that this standard, if adopted, would have the potential to affect the largest animal feeding operations (Class IA operations), particularly operations using anaerobic lagoons.
Many industries are specifically required to report emissions in the rule. The full implications of the rule are not yet clear. The sheer size of the proposal (over 1400 pages) means that it will take some time for everyone involved to read and understand the proposal. This rule does not propose any type of tax or limit on greenhouse gas emissions. It is a proposal to monitor greenhouse gas sources. That said, monitoring is viewed by many as a logical first step to implementing some type of greenhouse gas emission limits.
The proposal will be published sometime within the next month in the Federal Register. A 60-day period for public comment on the rule is anticipated starting on the Federal Register publication date.
MU Extension is working with other agencies and stakeholders in Missouri to understand the implications of this rule on Missouri farmers. We will be providing more analysis on the proposed rules in the coming weeks. For links to the proposed rule and more information visit the web site http://nmplanner.missouri.edu/regulations/greenhouse_gas.asp
REVISED: April 6, 2012