WASHINGTON — On June 25, a coalition of food and farm trade associations, including the American Feed Industry Association, American Meat Institute, National Chicken Council, National Council of Farmer Cooperatives, National Grain and Feed Association, National Meat Association, National Oilseed Processors Association, National Turkey Federation and North American Millers Association, wrote to U.S. House Speaker Nancy Pelosi and Minority Leader John Boehner on the group’s opposition to climate change legislation that emerged from the Energy and Commerce Committee.

Such legislation may negatively impact the ability to place safe, abundant and affordable food on the tables of all Americans, they claimed.

"Climate change legislation will have significant direct and indirect impacts on the nation’s supply chain of food and beverage providers, and, in turn, profound impacts on the food security of our nation," the letter stated. "Legislative approaches must be carefully crafted not only to reduce greenhouse gas (G.H.G.) emissions, but also to avoid adverse impacts on food prices and food accessibility."

The letter pointed out while food, feed, and beverage producers account for 1.21% of the nation’s direct G.H.G. emissions, the group said it will be more affected by cap-and-trade legislation than this suggests.

"All members of the food-supply chain are disproportionately vulnerable to indirect costs passed through by suppliers," the letter continued. "When considering the total G.H.G. emissions from each sector, including suppliers, the food, feed, and beverage sector has the fourth-largest exposure to carbon costs—more than the chemical, retail, basic resources, and automobile and parts sectors. The food, feed, and beverage sector is also exposed to significant trade pressure. Yet, to date, Congress has not accounted for these disproportionate impacts on a sector that provides indispensable goods to American families."

Coalition members relayed they believe cap-and-trade will work best if allowances are distributed proportionately to each industry’s emissions, thereby mitigating the direct and indirect impacts on all regulated industries. A fair distribution of allowances would allocate an appropriate percentage of allowances to the food, feed, and beverage sector, the coalition conveyed. It would also avoid the impression that the allowances represent subsidies to favored industries—an accusation that could subject the U.S. to World Trade Organization disputes and American companies to retaliatory tariffs.

While the coalition agrees with developing a program to help offset increases in energy costs, it added the same consideration should be given to food. "The impact of rising domestic food prices will fall most heavily on the poorest 20% of Americans who spend roughly one-third of their after-tax income on food," the letter stated.

Coalition members also intend to discuss other issues with H.R. 2454, including "the inappropriateness" of Clean Air Act regulatory authority for numerous facilities that emit less than 25,000 tons of CO₂ per year; limitations on opportunities for offset projects; and tax and trade ramifications.

The letter concludes by asking members of Congress not to support passage at this time.