Dear Sir or Madam:
The American Bakers Association (ABA) submits this brief comment letter in response to the above referenced Federal Register notice soliciting information on biogenic emissions as the Environmental Protection Agency (EPA) considers how to account for greenhouse gas emissions for biogenic sources. The American Bakers Association is the Washington D.C.-based voice of the wholesale baking industry. Since 1897, ABA has represented the interests of bakers before the U.S. Congress, federal agencies, and international regulatory authorities. ABA advocates on behalf of more than 700 baking facilities and baking company suppliers. ABA members produce bread, rolls, crackers, bagels, sweet goods, tortillas and many other wholesome, nutritious, baked products for America’s families. The baking industry generates more than $70 billion in economic activity annually and employs close to half a million highly skilled people.
EPA specifically asks for comments regarding other biogenic sources of carbon dioxide (CO2) that are not related to energy production and consumption. 75 FR 41176. ABA offers the below comments for the Agency’s consideration as it determines how best to address biogenic emissions under a greenhouse gas regulatory scenario.
I. Background
Our members have a critical interest in the development of a carbon footprint reduction program, particularly as it may impact the sustainability of their businesses. According to the U.S. EPA’s own calculations, the food industry represents a relatively insignificant portion of emissions that contribute to climate change. In its “Technical Support Document for Food Processing Facilities,” the U.S. EPA estimates that methane emissions from wastewater treatment and landfills in the food processing source category totaled merely 10.9 million metric tons CO2e per year. Taking the total nationwide net (sources and sinks) CO2e emissions in 2007 of 6,087.5 million MT CO2e, one can calculate that emissions for the food processing industry (excluding emissions from on-site combustion of fuels) constituted less than two tenths of one percent (merely 0.179%) of net total emissions, and emissions from the baking sector specifically are, in turn, only a fraction of overall emissions from the food processing industry sector. Although these emissions are relatively small, the cost of measuring, auditing and regulating biogenic emissions will impose a heavy burden on the baking industry, adversely affect food prices, lead to job losses, and result in no environmental benefit. Climate change regulations should focus on significant GHG sources, not numerous small sources that would impose burdensome costs without achieving a corresponding benefit. ABA members have 696 baking operations nationwide. While some are larger companies, many are small and medium size businesses, each of which will be indirectly impacted by increased fuel, ingredient and yeast prices as a result of additional regulations. The Agency’s applicability thresholds set forth in the Mandatory Greenhouse Gas Reporting Rule and in the Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule have not, at this point, impacted many ABA members. However, if the EPA moves forward with lowering the thresholds to 10,000 tons/year, as some have suggested, many of these small and medium size bakeries will be impacted. While we support pragmatic solutions that incentivize voluntary reductions in energy use and GHG output, these smaller sources lack the administrative, technical and capital resources for implementing this type of program.
II. Biogenic Emissions from Living Organisms (e.g., Yeast) and Their Processes (e.g., Dough Fermentation)
Of the already minimal emissions from the baking sector, an even smaller part consists of organic “biogenic” carbon dioxide emissions from the natural process of yeast fermentation. As discussed in more detail below, we believe EPA should explicitly exempt emissions from biogenic sources such as yeast activity and dough fermentation entirely from any Clean Air Act programs.
Many bakery products, particularly foods that rise such as bread and sweet goods, are made with yeast. Yeasts are single-celled fungi–living organisms that need food, moisture, warmth and air to survive and grow. Yeast cells digest sugar, their appropriate food source, in a natural biological process known as fermentation, during which energy is released to the organisms and CO2 is formed as a byproduct. Various forms of sugars can be utilized by yeasts, including sucrose (beet or cane sugar, corn syrup), fructose and glucose (found in honey, molasses, maple syrup and fruit), and maltose (derived from starch in flour). In addition to bakery products, many other foods and beverages are produced through involvement of yeast fermentation processes. These include items such as beer, wine, vinegar, cocoa, chocolate, cheese, fermented milk and meat products.
Yeast is the most commonly used leavener in bread making, and it serves three main functions in this process. First, CO2 production during yeast fermentation results in stretching and expansion of the dough leading to the characteristic open structure of the final bread product. Second, other natural chemical activities that occur during yeast fermentation contribute to dough development by strengthening the flour in the dough so that it better captures and holds the CO2 that is produced. Finally, yeast fermentation provides distinctive flavors, aromas and texture to baked goods. As bread dough is baked, the CO2 that was produced through yeast activity is released from the bread. This CO2 then enters the carbon cycle, where it again becomes available to plants (including sugar cane, beets or corn from which more sugar for future yeast fermentation processes is produced) for use in their photosynthesis activities.
Accordingly, in a life-cycle analysis, any emissions from yeast fermentation during bread making are carbon-neutral and should not be counted as industrial emissions in a regulatory system.3 Indeed, this emission of CO2 is similar to that resulting from the natural respiration of animals, including livestock and humans, and other biological emissions which are not considered as regulated emissions under climate legislation proposed in Congress.
If incorrectly crafted, greenhouse gas regulation could significantly increase the price of food –especially that of basic diet staples such as bread and other baked goods. Bakers already will face significant impact of EPA’s GHG regulations through the imposition of “indirect costs” in the form of increases in the prices of electricity, natural gas fuel, and ingredients such as flour and sugar, as well as increasing construction costs for new facilities or expansions. Imposing additional costs for direct emissions of CO2 from natural biological processes would significantly add to that expense for larger bakeries and yeast producers. While passing on costs to consumers is a last resort, bakers will need to look internally to determine where they can become leaner, which in the current economic times could regrettably mean loss of jobs and plant closures. Even the European Union, which is widely viewed as overly aggressive in its regulatory burdens, has understood that climate regulation is not appropriate for the baking, and other food and agricultural sectors. The U.S. certainly need not go further than the Europeans in imposing emissions restrictions.
III. Conclusion
ABA strongly believes the Agency’s intent is to seek pragmatic solutions for addressing GHG emissions from industrial sources. We encourage EPA to consider the impact of regulating biogenic emissions would have on the baking industry, in particular our smaller and medium size bakeries. Bakers will already face the “indirect cost” of regulating GHG emissions large industrial sources as those sources consider fuel switching to natural gas–a feedstock that supplies our baking ovens. Unfortunately for the baking industry, there is no option to switch ingredients, as yeast cannot be replaced and it is crucial to baking bread and baked goods that are widely enjoyed by consumers a part of a healthy diet.
ABA appreciates the opportunity to provide our suggestions to EPA as it considers how to address biogenic emissions. If you have any further questions, please let me know via phone at 202-789-0300 or via email at rzvaners@americanbakers.org.
Sincerely,
Rasma I. Zvaners
Policy Director
Source: American Bakers Association
