Bryan Tolar, President Georgia Agribusiness Council, Inc. P.O. Box 119 Commerce, GA 30529 Testimony ofthe Georgia Agribusiness Council in Opposition to the U.S. Environmental Protection Agency's Proposed Changes to the Carbon Pollution Standards USEPA Public Hearing Russell Federal Building Atlanta, Georgia

July 29, 2014

Good afternoon. My name is Bryan Tolar and Iam proud to be the President ofthe Georgia Agribusiness Council. The Council was formed in 1966 and we serve Georgia's diverse and complex agriculture industry representing over 850 membercompanies across the state. Icome before you todayto express ouropposition to the proposed changes to the carbon pollution standards. Agriculture production and processing is an energy intensive industryand this precedent-setting rule will have adramatic negative impactto agribusiness overhead. Whether it is ginning cotton, drying peanuts, irrigating farm fields or managing poultryand livestock housing, the substantial push to have natural gas as a more significant source ofelectricity production will substantiallydrive up costs for both natural gas and electricity.
By far, the most intensive agricultural use ofnatural gas is in the production ofnitrogen fertilizer, which is used on virtuallyevery majorcrop produced in the United States. In fact, natural gas represents approximately eighty percent ofnitrogen fertilizer production costs. Unfortunately,this rule will artificially increase the demand for natural gas by essentially mandating fuel-switching from coal to natural gas for powergeneration. This could ultimately result in highercosts fordomestic fertilizer manufacturers that rely on natural gas as the primary feedstock for the production of nitrogen fertilizers.

As energy consumers and producers of productsthatare essential to the nation's food production system, we are concerned with the arbitraryapproach EPA has employed to create national and state emission reduction targets. While some have boasted energy conservation will decrease costs, food and fiber production will surely see increased costs on the horizon with this rule. These are costs that cannot be passed on to consumers. They must be absorbed by the farmers and processors as they compete in a global market with othersthat do notface the same obstructions. Pushing regulations that drive up the cost ofagribusiness production is effectively making our country dependent on foreign sources forthe food and fiber sectors that built America. These regulations are stripping away ourcompetitive edge and handing itto China and Brazil on a silver platter. We strongly urge the Administration not to lose sight ofits stated commitment to an "all ofthe above" energy strategywhich is designed notto favor one fuel source overanother. Let technology and the market play a role in energy production and get the heavy hands ofgovernmentout ofthe way. Agriculture does notjust growfood and fiber, it also growsjobs and economic opportunity. In Georgia alone, agriculture accounts for nearly $80 billion in annual economic impactand employsover375,000 people. In almost two-thirds ofGeorgia's counties, agribusiness and directly related industries are the largest orsecond-largest economic engines. This economic engine needs our support, not marketplace manipulation like these proposed changes thatthreaten its sustainability. Thank you forconsidering our comments today.