First Name | Adam |
---|---|
Last Name | Lazar |
Email Address | adamlazar@gmail.com |
Affiliation | |
Subject | Agriculture in AB32 scoping plan |
Comment | Plain text version of comments follows; also included as an attachment in Microsoft Word. The text version below omits the footnote references in the Word document. *********** AB32 Proposed Scoping Plan and (Non) Regulation of Agricultural Emissions December 10, 2008 Submitted by: Adam Lazar (SBN 237485) 1726 Page St Apt. 3 San Francisco, CA 94117 On behalf of myself and the public interest, I respectfully submit these comments regarding agricultural emissions of greenhouse gases in the AB32 Proposed Scoping Plan. The AB32 Proposed Scoping Plan identifies agriculture and food processing as the source of 9% of California’s greenhouse gas emissions. Given the limited estimation of agricultural emissions by the ARB, and the omission of fertilizer-related emissions, this number is likely far less than the actual total agricultural emissions. With such a significant amount of GHG emissions at stake, no exception for agricultural sources should be made under AB32. Yet the Scoping Plan provides a near-total exclusion of agriculture from emissions reductions. Instead of providing meaningful regulation of this source, the scoping plan goes only so far as to provide for voluntary reductions through usage of manure digesters at CAFO dairy operations. The Proposed Scoping Plan foresees no mandatory regulation of agricultural sources in the short term, and the possibility of only a very limited degree of regulation in the long-term. Lest one think the ARB belives this to be meaningful emissions reduction, the measure is given no reduction credit short term and only 1 long-term. Even the extremely early-stage and speculative California High Speed Rail receives more credit. The Scoping Plan should include meaningful measures to reduce the methane gas from Concentrated Animal Feeding Operations. On the one hand, these measures could compel the manure digesters already described in the Plan, and should additionally include mandatory capture from enclosed cattle buildings at CAFO’s and covered storage for animal waste lagoons. Not only would such mandatory covering work in tandem with requiring waste digesters, resulting in an immediate reduction in methane gases, but it would have tremendous co-benefits for public health from the reduction in airborne particulate matter. Likewise, prohibiting the open exposure (e.g. drying) of animal waste would further reduce methane and particle emissions. All of these controls could be required in a meaningful regime of agricultural emissions reductions. However, given the market-based leanings of the AB32 Scoping Plan, the best solution may be to include agricultural emissions in the cap-and-trade system. Methane capture is an accepted practice with over thirty participating dairies in the Central Valley alone. A recent study of Central Valley dairies concluded that many digester systems are already on the market. Notably, the study concludes that GHG emissions from CAFO’s should be included in a cap-and-trade system. When integrated into cap-and-trade, the study finds that the GHG offsets combined with electricity generation create a positive cash balance for a farmer. Given this potential, the ARB should not hesitate to bring agriculture under the system. Co-Benefits of Improved Waste Holding Requirements for Methane and Particulates Methane capture at CAFO’s is perhaps unique in the tremendous co-benefits afforded by its process; these co-benefits include both energy production and a major decrease in regional airborne particulate matter. A critical missed co-benefit in the AB32 Scoping Plan is the improvement in air quality from isolating animal waste lagoons from direct exposure. This isolation is a complimentary result to instituting a waste digestion system in a CAFO’s as considered as a voluntary measure. Need to Include Fertilizer-Related Emissions In Agricultural GHG The Plan credits these emissions to “largely methane emissions from animals and their waste.” However, agricultural fertilizer application should also be included in this sum, which would be no small addition—as much as 90 million metric tons of CO2 per year are used by CAFO’s, a full half of which is attributable to food crop production. Further, at least one study notes that fertilizer must be included in the emissions regulatory regime because otherwise the methane capture practices “could induce secondary effects that diminish water quality (e.g. switching to crops with greater fertilizer requirements.)” Even so, the study concludes that between 60 and 70 million tons of crop-related carbon emissions can be mitigated—while leading to a 2% improvement in water quality. Even with the inclusion of fertilizer, however, the Scoping Plan underestimates the contribution of CAFO’s to localized and highly concentrated greenhouse gas emissions in California. The plan does not acknowledge that California’s Central Valley contains the highest concentration of dairy CAFO’s in the world, leading to an inordinately high level of localized greenhouse gas emissions. Combine this concentration with a recent study delineating the contribution to greenhouse gas emissions from agricultural sources that “surpass those of the transportation sector,” and it is reasonable to conclude that agricultural emissions contribute far more than 9% of state greenhouse gas emissions. Conclusion Do not give agriculture an exception to AB32. The California Legislature made no such exception in their legislation, and the ARB’s exclusion of this sector from the Scoping Plan is a violation of the letter and intent of the law. Global farm animal production is expected to double by 2050. We must act now to combat this challenge. |
Attachment | www.arb.ca.gov/lists/scopingpln08/1628-alazar_agricultural_emissions.zip |
Original File Name | Alazar agricultural emissions.zip |
Date and Time Comment Was Submitted | 2008-12-10 11:26:16 |
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