National Association of Wheat Growers (NAWG) has submitted its responses this week to a House Agriculture Committee questionnaire on climate change, emphasizing Association policy supporting a cap-and-trade program that allows unlimited agriculture sequestration. NAWG responses include:
- A cap-and-trade program is the most effective approach to addressing climate change issues because this type of program would be a market-based system and able to provide the least costly means of delivering the greatest possible amount of greenhouse gas reductions.
- Agriculture and forestry should not be considered a capped sector under greenhouse gas legislation because emissions from this sector are too small and diffuse to regulate in a cost-effective manner.
- A cap-and-trade program should pre-empt various voluntary programs currently in existence.
- While the Environmental Protection Agency (EPA) should have authority to administer the larger cap-and-trade program, USDA should exercise its statutory authority from the 2008 Farm Bill to administer the development and implementation of agriculture and forestry offset policies.
- Offset projects should be assessed for quality based on criteria developed pursuant to the environmental services markets provisions in the 2008 Farm Bill.
- Legislation can be fashioned in such a way to provide both an economic benefit through the sale of agriculture and forestry carbon credits and use of the allowance pool to mitigate against any possible increases in input costs caused by greenhouse gas legislation. This is far preferable to the regulatory approach, which the EPA currently has under consideration to respond to a 2007 Supreme Court ruling determining carbon dioxide can be regulated under the Clean Air Act.
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