Comment Log Display

May 25, 2016

Mary Nichols, Chairwoman
California Air Resources Board
1001 “I” Street 
Sacramento, CA, 95814

Re: Conversion to Pastured Dairy in the Proposed Short-Lived
Climate Pollutant Reduction Strategy

Chairwoman Nichols:

The Natural Resource Defense Council and our partners in the
Grasslands Alliance would like to commend the California Air
Resources Board for taking a proactive approach to reducing the
short-lived climate pollutant emissions from the livestock sector.
The plan places a well-warranted focus on reducing manure methane
emissions from our dairy sector, which is not only low-hanging
fruit for California’s methane emissions, but will also result in
significant additional ecological (e.g., reduced surface and
groundwater pollution) and economic (conversion of manure into
renewable energy and fertilizer) co-benefits and help the state
achieve multiple policy objectives. 

Regarding the proposed strategy’s support for conversion of small
and mid-sized dairies to pasture-based management systems, we
recommend that to achieve the intended methane-reduction benefits
while minimizing the potential to increase other sources of
heat-trapping emissions (and additional environmental impacts
associated with poorly managed grazing), the policy should
incentivize conversion to “well-managed” pasture-based systems. In
the proposed strategy, your team did an excellent job of capturing
several reasons for our recommendation, including the fact that
pastured operations (especially if grazing management, feed
selection and breed selection are not optimized explicitly to
reduce and minimize ALL heat-trapping pollutants) can increase the
amount of enteric methane emissions per unit of milk.  

Two additional ways that conversion to pasture-based management can
increase greenhouse gas emissions are: 
•	poor grazing management that does not evenly distribute deposited
nutrients (from urine and dung) can create nitrogen hot spots
characterized by high nitrous oxide emissions; and
•	While well-managed grazing can sequester carbon in soils (with
soil carbon sequestration potential also dependent on factors such
as climate, soil characteristics, and land use history), poorly
managed grazing that increases erosion can oxidize significant
amounts of soil carbon, releasing it into the air as heat-trapping
CO2 emissions.  

Fortunately, well-managed grazing operations – by optimizing
grazing management, feed production and selection practices, and
breed selection, can reduce and minimize the full suite of
emissions from dairy and other livestock operations.

Opportunity to Pilot the new Grasslands Alliance Standard: A
Practical Guide to Sustainability of Grazing Operations in the US.
and Canada

In order to incentivize and enable California’s dairy (and beef)
producers to transition to verifiably “well-managed” pasture
operations, we invite you to partner with the Grasslands Alliance
by conducting pilot audits of our new sustainability standard for
grazing operations in the U.S. and Canada (described in the
attached PDF Standard overview). This new comprehensive standard
includes “Climate-Smart Ranching and Farming” as one of its six
principles. Specifically, the standard can be used as a tool to:
•	Recognize livestock operations that have optimized grazing, herd,
land, and nutrient management to reduce
and minimize their
carbon footprint and net emissions of greenhouse gases. 
•	Encourage well-managed grazing
and other management
activities that reduce emissions
of carbon dioxide, enteric
and manure methane, and nitrous oxide, while increasing carbon
sequestration to the site’s potential. 
•	Guide operations in optimizing feed and breed selection to reduce
and minimize emissions of methane (enteric and manure) and nitrous
oxide (emitted from manure and fertilizer management). 
•	Incentivize operations to reduce and minimize land use-related
CO2 emissions, including by (a) avoiding conversion of natural
ecosystems to croplands, pastures, and other forms of development;
(b) restoring degraded lands and croplands to perennial pasture;
and (c) utilizing conservation tillage, no-till, and other
practices (where applicable, e.g., compost application) that
increase carbon sequestration. 
•	Recognize operations that manage nutrients and manure in a manner
that proactively reduces methane and nitrous oxide emissions. 
•	Recognize operations that achieve additional emissions reductions
by improving energy and fuel efficiency, using renewable energy,
and reducing use of petroleum-based inputs. 

Since the above climate-smart ranching and farming strategies focus
primarily on improving production efficiencies, management quality,
and resilience to extreme weather, they offer economic
opportunities to producers and help mitigate business risks. 

Please contact us to learn more about how we can collaboratively
pilot the new Grasslands Alliance standard for recognizing and
incentivizing well-managed pasture operations.
  
Sincerely,

 
Jonathan Gelbard, Ph.D.
Conservation Scientist & Sustainable Agriculture Specialist
Natural Resources Defense Council
jgelbard@nrdc.org