American Council for an Energy-Efficient Economy
Suzanne Brooks and R. Neal Elliott. Agricultural Energy Efficiency Infrastructure: Leveraging the 2002 Farm Bill and Steps for the Future. July 2007.
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Center for Food Safety (CFS) and the Cool Foods Campaign (CFC)
Comments on the EPA Proposed Rule “CERCLA/EPCRA Administrative Reporting Exemption for Air Releases of Hazardous Substances from Animal Waste,” 2008.
CFS and CFC challenge the EPA’s proposal to exempt reporting of these substances based on documented human health and environmental risks due to hazardous air pollutants from animal wastes. CFS and CFC determine EPA’s action to be negligent to their duty to protect public and environmental health and contrary to the general mission and statutory responsibility of the agency. The comments contain detailed documentation of the various hazardous chemicals that are present in each of the animal agriculture sectors and their risks for worker, community, and environmental health. The comments conclude that EPA’s responsibility to address climate change will require more, not less, urgent government action and oversight.
Center for Food Safety and International Center for Technology Assessment
Comments on EPA Mandatory Greenhouse Gas Reporting Rule, 2009.
The Center for Food Safety (CFS) and its sister organization the International Center for Technology Assessment (ICTA) respond to the EPA’s request for public input on the Mandatory Greenhouse Gas Reporting Rule. In the proposed rule, the EPA establishes that large scale farms with manure management systems emitting greater than 25,000 tons of carbon dioxide equivalence (CO2e) would be subject to report their emissions. While the EPA should be commended for implementing a GHG reporting requirement, the threshold as currently proposed is too high to ensure the highest quality data is collected. To be consistent with legislation currently in the U.S. House of Representatives, CFS and ICTA recommend lowering the reporting threshold to 10,000 tons CO2e. Further, CFS and ICTA recommend that the EPA consider enteric fermentation in the reporting requirement, which is the greatest source of methane in the United States (U.S.). In order to draft and commit to a strategy for GHG reduction and climate change mitigation, the U.S. must rely on sound science for an accurate understanding of where emissions are coming from and the types of management systems associated with such emissions. Collection of such data will allow the U.S. to enable quicker dissemination of effective strategies.
Cool Foods Campaign
Comment Submission to the California EPA Air Resource Board on AB 32 (Global Warming Solutions Act) Scoping Plan, 2008.
In the fall of 2008, the CA-EPA ARB requested public comment on the draft scoping plant for the Global Warming Solutions Act. The Cool Foods Campaign (CFC) submission extensively details the evidence behind the role of agriculture in climate change. The CFC focuses specifically on the ways in which the food production, processing, and distribution systems contribute to climate change. Major areas of focus include: excessive water usage from irrigation and livestock facilities; methane emissions from confined livestock operations; inefficiencies in biofuel production; and the production, transportation, and utilization of synthetic fertilizers and pesticides. CFC recommends that industrial agricultural practices be re-examined to determine its true global warming impact. CFC also provides evidence for agriculture’s potential to mitigate and adapt to climate change through changes in agricultural and food systems at governmental, industrial, and household levels. Organic agriculture is highlighted as a solution to climate change, due to its documented ability to reduce GHG emissions across all sectors of the system – production, processing, and distribution.
Cool Foods Campaign
Comment Submission to the USDA’s Climate Change Strategic Planning Priorities and Goals for Research, Education and Extension, 2008.
The Cool Foods Campaign (CFC) responds to USDA’s request for public input on the Climate Change Strategic Planning Priorities and Goals for Research, Education and Extension. Within the comments, CFC highlights areas requiring greater research and provides background for the importance of sound scientific data from these areas to determine appropriate food and farm policy measures for climate change prevention, mitigation, and adaptation. Specifically, CFC focuses on the importance of thorough and extensive life-cycle assessments of the four major crop production systems: organic, conventional, organic no-till, and conventional no-till as well as research on various animal agriculture systems including grass-fed pastoral systems. Full life-cycle assessments include pre-farm, on-farm, and post-farm energy usage and emissions including such factors as: processing; packaging; on-farm energy use; enteric fermentation; land-use changes; manure management; food transportation; seed production, cleaning and transport; and the production, packaging, transportation, and application of synthetic and organic fertilizers and pesticides. This research would provide comparative data on the climate change impacts of various agricultural sectors and help shape future policy measures on climate change mitigation and adaptation strategy.
Cornell University College of Agriculture and Life Sciences
Antonio Bento and David Wolfe. Cornell Policy Brief: Creating a Role for Agriculture and Forestry in Emerging Carbon Markets. Dec. 2009.
Environmental Working Group
Craig Cox and Andrew Hug. Crying Wolf: Climate Change Far Greater Threat to Farmers than Climate Legislation. 2009.
Environmental Working Group
Loopholes in Climate Bill “Offset” Provisions Lets Major Polluters off the Hook. July 2009.
Greenpeace
David Sasson. Business as Usual: A Report to the President on Pending Federal Climate Legislation (ACES & CEJAPA). October 2009.
Iowa State University’s Center for Agricultural and Rural Development
Bruce A. Babcock. Costs and Benefits to Agriculture from Climate Change Policy. In Iowa Ag Review, Summer 2009.
Institute for Agriculture and Trade Policy
Steven Shrybman. Trade, Agriculture, and Climate Change: How Agricultural Trade Policies Fuel Climate Change. November 2000.
National Farmers Union
Handout: Principles for Ag Carbon Offset Legislation in Cap and Trade. April 2009.
National Sustainable Agriculture Coalition
Agriculture & Climate Change: Impacts and Opportunities at the Farm Level. 2008.
Pew Center on Global Climate Change
Innovative Policy Solutions to Global Climate Change: Agriculture’s Role in Addressing Climate Change. In Brief, No. 2.
Texas A&M University AgriLIFE Research & Extension
Joe L. Outlaw, James W. Richardson, Henry L. Bryant, J. Marc Raulston, George M. Knapek, Brian K. Herbst, Luis A. Ribera, and David P. Anderson. Economic Implications of the EPA Analysis of the CAP and Trade Provisions of H.R. 2454 for U.S. Representative Farms. AFPC Research Paper 09-2. August 2009.
World Resources Institute
Evan Branosky and Suzie Greenhalgh. Agriculture and Climate Change: Greenhouse Gas Mitigation Opportunities in the 2007 Farm Bill. March 2007.
World Resources Institute
Evan Branosky. Agriculture and Climate Change: The Policy Context. October 2006.
