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Indirectly it could be considered a cheeseburger tax, but one of the suggestions offered by the Environmental Protection Agency (EPA) in its Advance Notice of Proposed Rulemaking (ANPR) for regulating greenhouse gas emissions under the Clean Air Act is to levy a tax on livestock.

The ANPR, released early this year, would give the EPA the authority to regulate greenhouse gas for not only greenhouse gas from manmade sources like transportation and industry, but also “stationary” sources which would include livestock.

The New York Farm Bureau assigned a price tag to the cost of greenhouse gas regulation by the EPA in a release last month.

“The tax for dairy cows could be $175 per cow, and $87.50 per head of beef cattle. The tax on hogs would upwards of $20 per hog,” the release said. “Any operation with more than 25 dairy cows, 50 beef cattle or 200 hogs would have to obtain permits.”

Kate Galbraith, correspondent for The New York Times, noted on the Times’ “Green Inc.” blog that such a “proposal is far from being enacted” and that the “hysteria may be premature.”

But Rick Krause, senior director of congressional relations for the American Farm Bureau, warned it’s certainly feasible – especially based on the rhetoric of President-elect Barack Obama and the use of the EPA to combat global warming. Such action by an Obama administration would take an act of Congress for livestock to be exempt.

Even the Department of Agriculture warned the EPA that smaller farms and ranches would have difficulty with limits as much as 100 tons annually on emissions:

“If GHG emissions from agricultural sources are regulated under the CAA, numerous farming operations that currently are not subject to the costly and time-consuming Title V permitting process would, for the first time, become covered entities. Even very small agricultural operations would meet a 100-tons-per-year emissions threshold. For example, dairy facilities with over 25 cows, beef cattle operations of over 50 cattle, swine operations with over 200 hogs, and farms with over 500 acres of corn may need to get a Title V permit. It is neither efficient nor practical to require permitting and reporting of GHG emissions from farms of this size. Excluding only the 200,000 largest commercial farms, our agricultural landscape is comprised of 1.9 million farms with an average value of production of $25,589 on 271 acres. These operations simply could not bear the regulatory compliance costs that would be involved.”