Comment Log Display

Dear Governor Newsom and California Air Resources Board (CARB)
members,

On behalf of Family Farm Defenders, a national grassroots
organization based in Madison, WI with over 3000 members in all
fifty states, including CA, I am writing to you to express our
concern about CAFO biogas digesters being used to offset pollution
generated in your state through the Low Carbon Fuel Standard
(LCFS)

Pollution trading is fundamentally flawed in that it does not
actually require pollution reduction, but allows polluters to
instead shift their pollution impact to other communities.  Worse
yet, many of these supposed offsets have been shown to be bogus,
meaning that the over all climate change pollution impact is
actually worse.

This is certainly true in the case of CAFO biogas digesters,
supposedly offsetting carbon dioxide emissions by reducing methane
emissions, but in reality many of these biogas digesters are doing
neither.  In the case of WI there are over a dozen CAFO mega dairy
farms who have long been claiming methane offset credits under the
LCFS carbon market trading scheme.  Thanks to the diligent
oversight of many local citizen activists, we know that many of
these WI CAFO biogas digesters are not actually functional as
claimed and that methane is not being actually being reduced.  

When this corruption was exposed in the media, CA authorities had
to work hard to claw back the bogus offset credits from the WI CAFO
biogas digesters, but that should not be the belated response if
there was proper vetting and accountability mechanisms in place. 
Concerned private citizens should not have to be the watchdog for
taxpayer-subsidized government-created carbon/methane trading
offset markets. To be honest, such false offset claims in a
pollution trading market is tantamount to wire fraud and should
lead to federal prosecution.

Many of the mega dairy WI CAFO biogas digesters implicated in this
fraud have a long sordid record of breaking other state and federal
laws, including violations of labor laws (some farmworkers have
died at these facilities trying to work on the biogas digesters) as
well as numerous environmental regulations related to the Clean
Water and Clean Air Acts.  Some of our WI CAFO biogas digesters
have even blown up and been implicated in massive manure leaks
contaminating public water supplies, raising potential liability
concerns for anyone who may be financially connected - such as
those engaged in the CA LCFS carbon trading market.

As a national family farm organization, we would urge you to no
longer allow methane offsets in the LCFS market - these are dubious
(at best) and the mega dairy CAFOs claiming such credits are
causing serious harm to Midwest rural communities.  At minimum,
there should be no "grace period" allowed for such CAFO biogas
offset claims - their lousy track record hardly warrants such.  The
"life cycle" analysis of supposed methane emissions as a possible
offset for carbon dioxide emission needs to be seriously
reevaluated - especially if the credit claims are egregiously
overstated or even totally bogus.  

The best offset would be giving LCFS credits to rotational grazing
dairy operations (which are actually the most economically viable
and climate friendly here in the Midwest according to many studies
from the UW-Madison Center for Dairy Profitability), but that is
sadly not acceptable under the current LCFS carbon trading system. 
Apparently, if a family farmer does NOT create a methane problem in
the first place (by not confining their animals in a building and
then putting their manure into anaerobic lagoons) then they can not
get any taxpayer subsidized carbon credit for solving the climate
crisis.  

If the State of California is serious about reducing GHG emissions
through a pollution trading system, then they should not allow
corrupt CAFO operators across the country to take advantage of
shoddy oversight and lackadaisical accountability to bilk taxpayers
through bogus offsets.   We ask that you no longer shift your
pollution responsibility onto Midwest rural communities (or
anywhere else for that matter) and terminate the methane biogas
digester offsets in the LCFS program.