CRA advocates for a healthy and prosperous environment that preserves America’s ability to innovate and promote economic growth. CRA believes environmental regulations need to be guided by law and rooted in science. As a result, our industry supports policies that are stringent but workable across a range of important environmental issues, including air quality, water quality, pollution prevention, and toxins, as regulated by the Environmental Protection Agency (EPA) and United States Department of Agriculture (USDA).
CRA’s Climate Change Policy Principles guide the industry’s advocacy to ensure a more sustainable future for corn refining, agriculture, and consumers.
Our five principles can be viewed here.
These principles will drive advocacy for science-based public policies that demand economically-sound decisions at the state, federal and global levels.
Improving air quality is a top priority, not just for CRA, but across the manufacturing sector. American businesses spend billions of dollars annually on air quality protection, helping to achieve remarkable improvements, especially as technology evolves. As technology advancements outpace regulatory programs, CRA is working closely with regulators to ensure the Clean Air Act (CAA) is implemented consistently, with timely and cost-efficient permitting requirements and environmental and legal reviews. In addition, CRA members are focused on:
Biogenic CO2 Emissions: Biogenic CO2 emissions are emissions of crop-derived CO2. They result from the combustion of biomass or biofuels derived from herbaceous crops or crop residues, as well as biogenic CO2 emissions associated with the production, harvesting, and processing of crop residues. Since crops draw CO2 from the atmosphere as they grow, these emissions do not contribute to elevated atmospheric concentrations of greenhouse gases. Treating agricultural biomass in the same manner as fossil fuels will stifle the development of agricultural biomass, the bioeconomy, and bioproducts, undercutting their economic competitiveness and stunting their potential to displace fossil fuels and petroleum-intensive products.
National Ambient Air Quality Standards (NAAQS): The EPA Administrator is directed to study the effects of pollutants having negative impacts on public health and welfare and to establish NAAQS based on those studies. Because of these standards, corn refining facilities contemplating expansions or modifications that could trigger a NAAQS review must demonstrate that emissions from such a facility, when combined with background air quality, do not exceed the applicable NAAQS standard. The EPA has recently tightened the NAAQS for particulate matter, sulfur dioxide, nitrogen oxide, and ozone. As NAAQS are set closer and closer to background air quality levels, it is becoming more difficult for corn refining plants to receive permit approvals. Further complicating this situation, the EPA did not issue implementing guidelines for its 2008 standards until 2015. As a result, states are now facing the prospect of implementing two different standards simultaneously. In response, CRA and its members advocate for the improvement and modernization of the implementation process for EPA NAAQS.
With passage of the Clean Water Act in 1970, Congress sought to restore and enhance our nation’s water. Since then, and with the help of technological innovation, industry sources have significantly reduced their impacts on arguably the most important natural resource this world has to offer. As a result, many of the nation’s waters previously labeled “impaired” are now restored.
In order to ensure continued progress, CRA’s member companies work tirelessly to find new and innovative ways to efficiently reduce pollution and comply with the law.
As part of that process, CRA advocates for a workable definition of Waters of the United States (WOTUS) that protects the environment and will withstand court challenges. The Obama Administration’s proposed Clean Water Rule did not meet that test, as it would have required manufacturing facilities to obtain a Clean Water Act permit and be subject to federal regulation for activities near snow melt and prairie potholes, in addition to direct discharges into navigable waters.
Consumers, suppliers, and government regulators increasingly demand carbon scores for a wide range of products. CRA has a keen interest in ensuring the GHG accounting methodologies used and the resulting scores for bioproducts made from corn are appropriate. The Argonne National Lab’s Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) is a widely cited life cycle analysis model that can be applied to fuel and non-fuel bioproducts. Currently, corn-derived dextrose is not designated as a feedstock for determining carbon intensity (CI) values in the model. As a result, dextrose-derived bioproducts carry a heavier burden of the CI score than they would if dextrose had its own pathway. CRA leads an effort with staff at Argonne to add a dextrose pathway to the GREET model, which will provide dextrose users an accurate accounting of the carbon intensity of their feedstock.