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Sir: I am enclosing a comment for your consideration that utilizes
COD as a substitution methane metric for L1.1.3 in the LOP for
dairy manure. 

There are numerous dairies that utilize diluted wash down effluent,
which is then screened for solids prior to discharge to the lagoon.
The solids are utilized for nutrition management. 
However, there is a sizeable decrease in VS in the effluent due to
the screening, which underreports the CH4 emissions in the
baseline. 
We are proposing COD, a known substitute currently used by IPCC to
determine emissions. It is insensitive to screening procedures and
would provide an accurate assessment of the baseline and project
performance in BCS systems that process diluted effluent. 

I have attached a detailed briefing for your review. 

Best Regards, 
Don Yochum
Trane Energy Services