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Given that California’s dairies are the primary source of methane
emissions in the state (CARB Short-lived Climate Pollutant
Reduction Strategy Concept Paper), Straus Family Creamery
recommends that methane digesters be mandated on all dairies in
California with a herd size of more than 100 cows by the year 2020,
provided that a viable third-party ownership model for methane
digesters is established. Due to the risk and time burdens
associated with owning and operating digesters, a third-party
ownership model that supports long-term operations of 20 years+ is
recommended as an option for dairies. This type of arrangement
allows the dairy operator to be responsible only for the supply of
waste; and not for paying capital costs, nor for the time and
expertise needed to run a digester operation. Dairy operators would
thus have the choice of owning and operating a digester themselves,
or of having a third-party own and manage the digester, to meet the
mandate. We also recommend incentivizing co-digestion in regions
with a high number of dairies. Additionally, co-digestion could be
expanded to multiple waste streams, to realize dual benefits of
reducing methane from dairies and landfills, where the opportunity
arises. Lastly, we recommend including incentives that support
research and demonstration projects to reduce emissions of bovine
enteric methane, which account for an estimated 29% of all methane
emissions in the state (CARB 2013 GHG Inventory).

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Date and Time Comment Was Submitted: 2015-11-12 15:38:31