Comment Log Display

To the CA Air Resources Board,

CARB has again largely ignored enteric emissions from livestock in
the development of its SLCP Reduction Strategy and DEIS. Enteric
emissions constitute about 30 percent of methane emissions in
California in a normal year. It is unconscionable that this methane
source (about a billion pounds of methane emission per year in
California) continues to be severely neglected by CARB when there
are reasonable measures that could be enacted to dramatically
reduce methane emissions from this source.

I propose again that CARB, the legislature, and the Governor
explore and consider enacting some or all of  the following:
measures to promote mandatory livestock herd size reduction;
requirements that cattle shall wear plastic backpack technology
that captures the emitted methane so it can be burnt rather than
belched into the atmosphere while they graze in the pastures
[http://www.fastcoexist.com/.../these-backpacks-for-cows...,
http://www.dailymail.co.uk/.../Now-THATS-wind-power-Cows... ,
http://grist.org/.../crazy-clip-shows-what-happens.../...];
mandates that compel the development of enclosed
barns-vented-to-biofilter treatment systems that capture emitted
dairy-associated methane before it escapes into the atmosphere. 

Enteric fermentation methane emissions from dispersed,
pasture-based livestock should also be considered for incorporation
within cap and trade (with pollution permit costs to ranchers based
on a short-term interval methane Global Warming Potential [GWP]
value). For dairy CAFOs, there should be meaningful, mandatory
reduction targets established for enteric emissions from livestock.


Finally, and more generally, a stiff tax should be imposed on all
other sources of uncaptured, unburnt methane emitted into the
atmosphere that are not included in cap and trade. The tax should
be based on the use of a short-term interval methane GWP. Since the
best scientific estimate for the actual physical lifetime of
methane in the atmosphere is a little over 12 years (12.4 years,
IPCC AR5th 2013), a methane GWP of 100 should be used, as that is
the approximate methane GWP associated with the 12.4 year
interval.

On a planet that is rapidly heating and undergoing significant
anthropogenic climate disruption, we can no longer remain passive
in the face of livestock and dairy industries that continue to
externalize significant enteric-emission-related methane pollution
costs onto the broader global environment. 

Sincerely,

Todd Shuman, Wasteful Unreasonable Methane Uprising, Camarillo