First Name: | Todd |
---|---|
Last Name: | Shuman |
Email Address: | tshublu@yahoo.com |
Affiliation | |
Subject | Comment on Aliso Canyon Climate Impacts Mitigation Program Draft |
Comment |
To CARB, I am now resubmitting some of my previously-submitted comments concerning this matter, which focus on enteric-related methane emissions from livestock. The CARB draft concerning the Aliso Canyon Climate Mitigation Strategy completely ignored measures that might or would significantly lead to a reduction in enteric emissions from livestock (the largest source of methane emissions in California!) CARB also ignored previously-submitted comments concerning methane taxes/fees that would also likely reduce methane emissions from multiple sources. I request again that CARB address these issues before issuing a final document Sincerely, Todd Shuman, Wasteful Unreasonable Methane Uprising, Camarillo, CA 805.987.8203 Subject: Aliso Canyon Climate Impacts Mitigation Program On behalf of Wasteful Unreasonable Methane Uprising, I submit the following recommendations concerning the Aliso Canyon Climate Impacts Mitigation Program: 1: SCGC/Sempra shall be required to heavily subsidize the widespread construction of freestall dairy barn enclosures with methane captured and vented to biofilters in California. 2: SCGC/Sempra shall be required to heavily subsidize a fund that will finance livestock herd size reduction in California (in order to reduce statewide, cattle-related enteric methane emissions) and enable the meaningful mitigation of environmental justice-related impacts associated with dairies and gas wells throughout California. 3: CARB shall consider instituting or developing or promoting a Methane Fee, in either of two forms presented below: A: "All those legally responsible for the generation of more than 40 pounds of uncaptured, unburnt methane emissions per year shall be required to pay an annual fee on each ton of uncaptured, unburnt methane emission for which they are responsible. The fee shall be 100 percent of the baseline value of $4700 of damages per ton of methane (in 2007 dollars) that is presented in The social cost of atmospheric release, Drew T. Shindell, Climatic Change (2015) 130:313–326, DOI 10.1007/s10584-015-1343-0, page 319, Table 2, Median total; declining rate." This approach would result in a methane price per ton paid by those responsible for methane emission of approximately 4700 dollars per ton, in 2007 dollars (or 5372 dollars, in 2015 dollars). (See http://www.usinflationcalculator.com/.) B: "All those legally responsible for the generation of more than 40 pounds of uncaptured, unburnt methane emissions per year shall be required to pay an annual fee on each ton of uncaptured, unburnt methane emission for which they are responsible. The fee shall be based upon a methane-into-CO2-equivalency conversion algorithm/calculation that incorporates the most recent scientifically-defensible 10-year interval methane GWP constant (at best) or 20-year interval methane GWP constant (at worst). The methane GWP constant used for such calculations should also incorporate climate-carbon feedbacks." This approach would result in a current methane price per ton of approximately 1120 dollars per ton. (Current price of CO2e [$13/ton] X 86 [20-yr methane GWP, IPCC AR5th]. See http://calcarbondash.org/. 4: Additional measures should also be enacted that would require SoCalGas/Sempra to finance reductions in methane emissions from other sources, including pneumatic devices, pumps, and compressors used within the natural gas industry itself. Sincerely, Todd Shuman, Wasteful Unreasonable Methane Uprising, Camarillo, CA 805.987.8203 |
Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2016-03-24 12:52:59 |
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