Comment Log Display

My name is Sandra Lupien. I live in Oakland, where I work for Food
& Water Watch, a national advocacy organization with about 170,000
supporters in California. Thank you for your work on the
Short-Lived Climate Pollution Reduction Strategy and for the
opportunity to comment on the draft. 
 
First, we applaud the California Air Resources Board’s move to make
California the first state to require factory farms to reduce their
emissions of methane and other short-lived climate pollutants.
Mandating such reductions is an important first step toward making
polluters accountable for protecting the climate and the health of
Californians. Food & Water Watch and many other public health and
social justice organizations asked the Air Board to include such
mandated reductions in the short-lived climate pollution reduction
strategy, and we are pleased you agree this approach is necessary.
Thank you.

However, we are very concerned that the proposed strategy relies
heavily on the use of methane digesters, which are not an effective
long-term solution to methane emissions from factory dairies. This
expensive technology frequently results in leaked methane and other
greenhouse gases like carbon dioxide and nitrogen oxide, which
cause smog and public health issues like asthma. Furthermore,
methane digesters fail to address the root cause of methane
pollution from factory dairies, which is, of course, too many
animals producing an unmanageable quantity of manure-based and
enteric methane. As the Air Board moves toward implementing the
proposed strategy in 2017, we hope it will eliminate digesters as
an approach to mitigating methane, and instead work collaboratively
with appropriate state agencies to craft policies that reduce
methane emissions by promoting sustainable dairy operations in
California that emphasize pasture-based methods and appropriate
herd sizes. 

Finally, we are pleased that by mandating methane reductions by
factory dairy farms, the strategy would, if implemented, ensure
that such reductions are truly additional by eliminating new
projects from eligibility as offsets to be sold in the state’s
cap-and-trade market. In order to ensure that the strategy achieves
its targets, we urge the Air Board to also remove existing projects
from the state’s cap-and-trade program instead of allowing them to
generate offsets for up to 10 years of operation. Likewise, we do
not support any generation of Low Carbon Fuel Standard credits for
any of these projects. 

Again, thank you for the opportunity to weigh in on the Short-Lived
Climate Pollution Reduction Strategy. Once the strategy is
finalized, we look forward to working with you to develop and
implement a regulation that will achieve the targets for methane
reductions from dairies while protecting communities.