Washington-Larry Herz, The Fertilizer Institute’s Vice President, Scientific Programs, has sent a letter to the U.S. Environmental Protection Agency expressing concerns that TFI comments on the Final Greenhouse Gas Inventory (2007) were not addressed in the final publication. “We at TFI are very concerned in that it appears that none of our comments were addressed in the Final Greenhouse Gas Inventory (2007) and that EPA only had six days from the close of the public comment period to final publication to review and respond to stakeholder and public comments and complete the document in final publication form,” said Herz. “That does not appear to be nearly enough time to adequately address stakeholder comments. A large concern for us still outstanding is the assignment of industrial urea emissions to the domestic fertilizer industry (recall that 60 percent of all nitrogen is imported from other countries) and that the percentage you are using (43 percent approximately) for industrial urea seems to be too high by 30 percent (TFI estimates that 13 percent of urea goes to industrial uses). Finally, EPA has yet to explain the change in calculation for these and other anomalies regarding urea.” Herz requested a meeting with the EPA team to discuss these issues and to better understand EPA’s path forward in regard to the handling of stakeholder comments.
Transparency Across the Fertilizer Value-Chain