Letters to the Editor
EPA Should Not Allow Methane Biogas From CAFOS to Serve as Qualified Feedstock, Source of e-RINS
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To the Editor:
Biogas from concentrated animal feeding operators (CAFOs) is harming underserved communities and the environment, and unfortunately, the transition to electric vehicles could cause a significant uptick in their use and their resulting impacts.
I serve as an Executive Co-Director of Green America, an organization that works nationally to create a socially just and environmentally sustainable economy. We represent over 250,000 consumers and 2,000 businesses nationwide.
Earlier this month I had the opportunity to testify before the EPA about its decision to provide a pathway for electricity produced from biogas and how it will come at the expense of communities, in particular Black and Brown communities. Allowing methane biogas from CAFOs to serve as a qualified feedstock and generate electric renewable identification numbers (e-RINS) under the Renewable Fuel Standard will create further pollution in these already overburdened communities.
Factory farms around the country are creating football field-sized pools of waste that expose surrounding communities to ammonia, hydrogen sulfide, and volatile organic compounds. These pollutants harm the health and lower the life expectancy of people who live nearby. A recent study found that air pollution from CAFOs results in 12,700 deaths per year. This industry could now gain even more profits from its pollution.
In addition, animal agriculture practiced in CAFOs is a major driver of climate change. Animal agriculture is the leading source of methane pollution, a potent greenhouse gas. Climate change is impacting communities across the U.S. and is impacting low-income and communities of color the most.
Green America and its members are very supportive of decarbonizing the transportation sector with electric vehicles. And to meet our nation's ambitious climate and energy justice goals, those electric vehicles must be tied to electricity derived from truly clean energy such as wind and solar power.
But implementing an electrification pathway for factory-farmed methane gas produced by CAFOs under the Renewable Fuel Standard would compound the suffering of rural communities. It would primarily benefit factory farms at the expense of local communities and prioritize profits over people.
This pathway also runs counter to the Biden administration's own prioritization of energy justice, which the EPA has taken significant steps to address overall. That's why we urge the EPA to prioritize energy and community justice and not allow methane biogas from CAFOs to serve as a qualified feedstock and source of e-RINS.
Todd Larsen
Executive Co-Director of Green America
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