Washington-TFI Vice President of Scientific Programs Bill Herz testified April 6 at an Environmental Protection Agency (EPA) public hearing regarding EPA’s mandatory greenhouse gas emissions reporting proposed rule. Herz outlined the process in which greenhouse gases are generated in nitrogen fertilizer manufacturing, and explained that the process is chemically fixed by nature and cannot be altered. Herz pointed out that acceptable options for utilization of carbon dioxide (CO2) are critical for successful reductions. Herz also urged EPA not to follow the agency’s greenhouse gas inventory paradigm of attributing urea emissions to the industry. In addition, Herz noted that EPA should not collect data on nitrogen percentage as it does not represent a suitable surrogate for estimating greenhouse gas emissions as emissions profiles are highly dependent on how the product is used. As an example of how appropriate agricultural best management practices may reduce greenhouse gas emissions, Herz suggested implementation of the 4R nutrient stewardship system, which promotes the use of the right fertilizer product, at the right rate, right time, and right place. Finally, Herz urged EPA to consider small businesses such as agricultural retailers, and to assist them by providing a blueprint that helps them understand whether they will have to report under the rule. TFI’s Herz also delivered a presentation regarding the potential impact of climate change policy on the fertilizer industry at an agriculture industry meeting hosted last week by the National Council of Farmer Cooperatives. Herz’s presentation provided an overview of how the fertilizer industry fits into the climate change policy debate, the potential cost of allowances under cap and trade policy, EPA’s mandatory reporting rule, and the activities and initiatives being undertaken by TFI regarding the issue.
Transparency Across the Fertilizer Value-Chain