Document RpQzRVd3Ejj1qQ5r5Y84aaMLE

IVlembars American Bakers Association American Farm Bureau Federation Corn Refiners Association Ejiginoity Worldwide National Com Growers Association iseuone; sa.a.rr.ai Council of America oarmnai sairrorisoeo Products Association National Oilseed Processors Association North American Millers' Association The Biogenic CO2 Coalition supports science-based recognition that agricultural biogenic CO2 emissions are not harmful greenhouse gases and opposes EPA's overreach in regulating sustainability on farms. Agriculture is key to the 21st century bioeconomy that includes feeding America and the expansion of bioproducts such as bioplastics, composites, and intermediates made from corn, oilseeds and other agricultural feedstocks. According to the federal government, the bioeconomy in 2013 was valued at $369 billion, provided 4 million American jobs, and was the leading source of domestic renewable energy. The bioeconomy is poised to expand exponentially with tremendous potential for economic development and job creation. When farmers grow crops, they store carbon (CO2) from the atmosphere, and when agricultural feedstocks are used for food, fuel and fiber, CO2 simply returns to the atmosphere in a natural biogenic cycle. Because of the benefits of agriculture as a renewable and sustainable resource, "biogenic" CO2 emissions from agricultural feedstocks are universally accepted as carbon neutral by policymakers and scientists, yet: EPA is ignoring science and treating biogenic CO2 emissions from farm products a "harmful pollutant" the same as fossil fuels. Practically speaking, EPA is putting a pollution tax on farm products, which imposes $$$ millions of unnecessary costs on users of farm products (think bakeries, brewers and grain processors) and energy generators (for example, corn stover used for electricity). If farmers want to avoid EPA's pollution tax, EPA says it can dictate what "sustainable" farm practices can be used to produce food products or energy feedstocks, which will require tracking compliance of every bushel of corn, wheat, soy or cottonseed from its source. Congress should stop EPA from ignoring science and blocking American agriculture and bioeconomy markets. Prompt relief is crucial, as development of the bioeconomy will not wait - if the U.S. does not move forward, other countries will dominate these markets. Our Request: Biogenic C 0 2 emissions from the use or processing of agricultural crops should be recognized as de minimis or zero under the Clean Air Act; and EPA should retract any attempt to regulate "sustainable" farming practices as a condition to feedstock eligibility under its Clean Power Plan (CPP) or Clean Air Act. About the Biogenic CO2 Coalition: The Biogenic CO2 Coalition, through its member national trade groups, represents a broad swath of agriculture and related sector constituents in advocating for sensible policies recognizing the carbon benefits of agricultural production and processing. www, BiogenicC02.org Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00087398-00001 Carbon Lifecycle of Agricultural Crops Crop-based feedstocks absorb carbon from atm ospheric CO? d (J ring t h e g rosst b e y e i <&. Processing Srspiy returns CO ; back lo ta the atm osphere in a carbon neutre! cycle. Once feedstocks are harvested they are turned into hioproducts such as food, fiber, blopiasttcs, and clean fuels. nginuity # NCPA N v\r a.t-s.\f, y ( o *.**-m ^ $xsyy-,:C"i s. y w .v. fetSI1, iw o y o c il Sierra Club v. EPA 18cv3472 NDCA www<BiogenicC02,org Tier 1 ED 002061 00087398-00002