12/13/2008 11:17:27 PM EST
Cow tax, a GHG emission urban myth?
As noted in prior posts, EPA has sought general input on the if and how of using the Clean Air Act (CAA) to regulate greenhouse gases (GHGs). Suddenly, EPA has been inundated with comments about a so-called EPA proposal to tax cows and sheep because these ruminants emit methane, which as noted in prior posts is a significant GHG. Was there such a proposal, or is mob panic at work? First, let's put the issue in perspective because methane from ruminants is not insignificant. Ruminant livestock produce about 80 million metric tons of methane annually, accounting for about 28% of global methane emissions from human-related activities. See http://www.epa.gov/rlep/faq.html. Second, the idea that a tax be placed on ruminants has been suggested elsewhere, specifically in and . See, for example, http://news.bbc.co.uk/2/hi/asia-pacific/3005740.stm. It was never implemented in light of considerable local opposition. As a matter of fact, a much more rationale approach to the problem with ruminant emissions is being pursued at a number of Universities and in the private sector, namely altering the efficiency of the metabolic process of ruminants or altering the bacterial composition of ruminant stomachs to decrease or eliminate the production of methane. See the following, for example, which discuss or refer to control strategies: http://ecoscraps.com/2008/06/09/sheep-and-cow-farting-vaccine-to-reduce-climate-changing-methane-emissions/, http://www.emissions.org/publications/member_articles/ef2ema24.pdf, http://www.rumeth.com/Ruminant-Methane-Efficiency-Methodology.php, and http://www.springerlink.com/content/2r70m048m7w2l6t2/. Somehow, someone hit the panic button. The New York Farm Bureau issued a statement saying it feared that a tax could reach $175 per cow, $87.50 per head of beef cattle, and upward of $20 for each hog. See http://www.nyfb.org/Press%20Releases08/PR-FB-EPA-11-26-08.pdf. Farm officials across the sounded the alarm, and the comments poured in to EPA. The hysteria is premature. E.P.A. did indeed issue, as noted in prior posts, an "advanced notice of proposed rulemaking" this summer that called for public comments on the idea of regulating greenhouse gas emissions from cars, as well as "stationary sources", which one could imagine could theoretically include cows and other ruminants (if they did not move around too much?). But, there is no such tax proposal, and the reaction appears more than a little premature. As noted above, the more reasonable approach is to address the methane generation issue directly, and (as they say) eliminate it at the source.