4/12/2022
The Honorable Liane Randolph,
Chair
California Air Resources
Board
1001 I Street
Sacramento, CA 95814
RE: American Biogas Council CARB Response April
2022
Dear Chair Randolph:
As the voice of the United States biogas
industry, we are writing today in response to the Methane,
Dairies and Livestock, and Renewable Natural Gas in California
Workshop (Workshop) held by the California Air Resources Board
(CARB) on March 29. The American Biogas Council (ABC) represents
more than 300 and 3,000 professionals throughout the biogas supply
chain that are dedicated to recycling organic waste into biogas and
soil products.
The ABC applauds CARB on presenting a
virtual Workshop that was attended by over 800 people and provided
an opportunity for a balanced discussion of the issues around the
California Low Carbon Fuel Standard (LCFS) and SB 1383 regulations
as they relate to the dairy and livestock industries. It was made
clear during the Workshop that reducing methane emissions from
dairies and livestock facilities is critical to California
achieving its climate goals. One of the keyways for CARB to ensure
reduced methane emissions is for CARB to continue to incentivize
the development of anaerobic digesters on dairy and livestock
facilities as well as support the use of biomethane from these
systems in the Low Carbon Fuel Standard (LCFS) and other programs.
Not only are anaerobic digesters and related technologies critical
to reaching California's climate goals, but continued support of
anaerobic digesters on dairies and other livestock operations is
also required by Senate Bill 1383 (SB 1383) (Lara, 2016) and
multiple other laws in California.
CARB staff presented several times
throughout the day on the structure, requirements and results of
the program thus far and recently released the last version of the
CARB “Analysis of Progress toward Achieving the 2030 Dairy
and Livestock Sector Methane Emissions Target” report.
According to this analysis the 2030 target of SB 1383 will not be
met without continued investment in dairy and livestock sector
methane reduction projects. The data indicate that it will cost an
estimated $75 million per year to meet the target if the current
split between the Alternative Manure Management Program (AMMP) and
Dairy Digester Research and Development Program (DDRDP) is
maintained.
Throughout the Workshop we heard from
commenters and speakers who were opposed to dairy and livestock
biogas and suggested that California could become carbon neutral,
with clean air, clean water, and provide environmental justice for
all Californians without an impact on the dairy and livestock
industries. Most of these speakers were associated with the
Leadership Counsel for Justice & Accountability and they failed
to provide specifics on how California would be able to achieve its
climate goals AND maintain the economic vitality and productivity
of the dairy and livestock sectors. Rather the commenters and
speakers used generalities to argue against what they consider
“factory farms” and “factory farm
gas”.
We also heard from several experts
working in the biogas industry and at state and federal agencies
working closely with the biogas industry. Many of them stated that
the LCFS program is working, and with increased support and
incentives it will meet the 2030 target of SB 1383 without
regulating dairy products and milk, the number one ranked commodity
product produced in the state of California or effecting the almost
$58 billion economy that California Dairy has
created.1
Many of these speakers mentioned that the only proven
technology for significantly reducing emissions is anaerobic
digestion (AD) and that, where possible, pasture based dairies have
already been implemented. They pointed out that the
Intergovernmental Panel on Climate Change (IPCC) recognizes AD as
the leading technology to address climate change. Dairies have made
incredible progress as a sector and AD has been proven to be the
most effective solution available today to solve many of the
climate-related issues in California.
The ABC would like to comment
specifically on the following issues that were raised during the
workshop:
Dairy
opponents have submitted a petition to CARB to exclude dairy
biomethane from the LCFS.
This petition, if accepted, would clearly
violate the following requirements of SB 1383 specific to dairy
biomethane:
·
The
requirement that CARB “develop a pilot financial mechanism to
reduce the economic uncertainty associated with the value of
environmental credits, including credits pursuant to the Low-Carbon
Fuel Standard regulations . . . from dairy-related projects
producing low-carbon transportation fuels.”2
·
The
requirement to adopt a mechanism to provide LCFS credits for 10
years to dairy biomethane producers that begin production before
the adoption of dairy methane regulations.3
·
The
requirement that the California Energy Commission recommend
measures to increase the production and use of biomethane, with
priority going to “fuels with the greatest greenhouse gas
emissions benefits, including the consideration of carbon intensity
and reduction in short-lived climate pollutants.”4
Accepting the petition would also violate
other California laws calling for in-state biomethane production
including:
·
AB 1900
(Gatto, 2012) requires that “the commission shall adopt
policies and programs that promote the in-state production and
distribution of biomethane. The policies and programs shall
facilitate the development of a variety of sources of in-state
biomethane.”5
·
SB 1122
(Rubio, 2012) requires the California Public Utilities Commission
(CPUC) to “encourage gas and electrical corporations to
develop and offer programs and services to facilitate development
of in-state biogas for a broad range of
purposes.”6
·
AB 2313
(Williams, 2016) requires the CPUC to “consider options to
increase in-state biomethane production and use.”7
·
SB 840
(Budget, 2016) states that for “California to meet its goals
for reducing emissions of greenhouse gasses and short-lived climate
pollutants, the state must . . . increase the production and
distribution of renewable and low-carbon gas
supplies.”8
·
SB 1383
(Lara, 2016) requires state agencies to “consider and, as
appropriate, adopt policies and incentives to significantly
increase the sustainable production and use of renewable gas,
including biomethane and biogas.”9 SB 1383 also requires the
Commission to “consider additional policies to support the
development and use in the state of renewable gas, including
biomethane and biogas, that reduce short-lived climate pollutants
in the state.”10
·
The
requirement that the CPUC consider “adopting a biomethane
procurement program focused on in-state and delivered
biomethane.”11
Not only would accepting the petition be
bad policy if one truly wants to make progress on reducing carbon
emissions, but there is simply no way to exclude dairy biomethane
from the LCFS without violating the unambiguous language and intent
of California state law. There is also virtually no way to meet the
40 percent methane reduction target without dairy digesters, which
are providing by far the greatest methane reductions of any
programs or investments to date.12,13
Biogas systems are
the number one technological approach to capturing and
utilizing baseline short-lived methane emissions from wastewater
and waste solids while also producing renewable energy and fuels
for additional greenhouse gas (GHG) reductions from fossil fuel
offsets.
According to a December 15, 2021, report
“Assessing California's Climate
Policies—Agriculture” published by the Legislative
Analyst's Office (LAO)14, CARB estimates that all DDRDP
projects (including those funded but not yet implemented) will
provide significant GHG reductions totalling 2.1 million metric
tons of carbon dioxide equivalents annually. The estimated emission
reductions for each project will vary based on several factors,
particularly the amount of manure flushed into the digester and the
end use of the biogas captured. CARB12,13 estimates that
the program reduces emissions at a state cost of $9 per ton, which
is one of the lowest costs‑per‑ton estimates among Greenhouse Gas Reduction Fund
(GGRF) programs. (For context, allowances under the cap‑and‑trade program—which puts a price on each
ton of GHG emissions in the state—sold
for about $28 per ton at the November 2021 auction.)
In CARB’s methodology, emission
reductions for DDRDP projects come from two major sources. First,
estimates include reductions associated with avoided methane
emissions – specifically, the methane emissions captured by
the digester that otherwise would have been released into the air.
According to information provided by CARB, more than 75 percent of
the estimated emission reductions are from avoided methane, though
the amount can vary depending on the project.
Second, estimates include reductions
associated with avoided CO2 emissions, which assume that
fossil fuels are displaced by the biogas (and biomethane) produced
by a digester. (We note that the combustion of biogas [and
biomethane] produces CO2 emissions, but these emissions
are not included in the state’s GHG inventory because they
are biogenic rather than from fossil fuels.) Given that most
digester projects upgrade biogas to biomethane for transportation
fuel, avoided CO2 emissions for most projects largely
come from the displacement of fossil fuels used in the
transportation sector. The current methodology also includes
avoiding CO2 emissions for projects that displace fossil
fuels in natural gas pipelines and in electricity and heat
generation.
Biogas systems, particularly those on
dairy and swine farms, have played and are playing a critical and
primary role in meeting the State of California and CARB goals
related to Short Lived Climate Pollutants. Biogas systems supply
low carbon intensity renewable transportation fuel to the LCFS
program for mandated and scheduled lowering of carbon footprint of
consumed transportation fuel in the state. For California to meet
the targeted and scheduled methane reduction goals for dairy farms
in the state requires that we utilize the proven and tested
technology that AD offers.
The adoption of biogas systems within the
LCFS program, both in-state and out-state, and their subsequent
critical role in meeting state goals, results from a now proven,
LCFS-driven, economic model. This model has allowed for
unprecedented private/public/farmer partnerships and allows
costs/revenues/risks and viability of project development to be
shared. This thriving ecosystem would not function properly if it
could only rely on farm investments.
The ultra-low carbon intensity (CI)
within the dairy and swine biogas sector is real and well-vetted
within the national laboratory-developed Greenhouse Gases,
Regulated Emissions, and Energy Use in Technologies (GREET) model.
As such, anyone who values science must appreciate their role in
meeting GHG and climate goals, and not selectively replace them
with non-scientific reasoning.
The low CI of these projects arises from
a combination of well-to-wheels carbon gains plus the methane
offsets from baseline methane emissions from manure management,
storage, and application. Methane offsets from baseline emissions
are a legitimate accounting practice as baseline, pre-biogas
systems emissions exist, and are largely removed through the
installation of the biogas system.
The United Nation’s IPCC recognizes
the methane reduction potential from AD as up to 99
percent15, and that, along with other Waste-to-Energy
technologies, if used with appropriate air emissions technology,
can produce clean energy. The IPCC acknowledges however, that if
not used properly they can exacerbate air quality
issues16 and can contribute to fugitive emissions that
may reduce GHG reduction benefits17. Appropriately, in
developing the LCFS regulation, CARB addressed these potential
adverse impacts. Per the LCFS regulation, all projects, including
biogas projects, are required to comply with all laws that pertain
to them, including those associated with air and water quality.
Furthermore, in determining a CI score and having it annually
verified by third party auditors, and approved by CARB, dairy and
swine biogas projects are required to account for any fugitive
emissions that may occur along with the emissions associated with
energy inputs necessary to operate the projects.
Some of the language used by those who want to eliminate
dairy and livestock sector methane reduction projects is
purposefully misleading.
Opposition Claim 1: Dairies
and livestock facilities are “Factory Farms” producing
“Factory Farm Gas”.
The continual use of the terms
“Factory Farm” and “Factory Farm Gas” when
referring to larger livestock facilities and the biomethane
generated from their AD systems, purposefully mischaracterizes the
true nature of these farms. As voiced by the California dairy
producers during the comment period of the workshop, the dairies in
California, as well as elsewhere in the U.S., are primarily
multiple-generation, family-run businesses with a long history of
ties to their respective communities. They employ people directly
and bring other important jobs, local spending revenues, and valued
nutritional products to those communities where they are located,
the nation and the world. This can be verified with data from the
USDA's National Agricultural Statistics Service (NASS) 2017 Census
of Agriculture, which stated that 38,007 of 40,336 dairy farms in
the United States are family owned (94.2 percent).18
Texas dairy farmer Sieto Mellema captured
the sentiment of many dairy producers when he said that when he
looks out among his 3,000 cows and thousands of acres of crops, he
does not see a factory. He sees a dairy farm that he and his family
run with the utmost care and respect for their animals and their
land. “Some people see our farm and they think it’s too
big to be normal, so it must be a ‘factory,’” he
said. “We do tours here all the time and everyone is
astounded with the care we provide our cows. Even people in a rural
town like ours (Dalhart) are amazed, so I can see someone in a
large city having this mindset. The term factory farm is
misleading, but it is just not understanding farming on the part of
people who say that. It hurts me to the core to hear my farm called
that, but all you can do is educate.”
In addition, according to the U.S.
Environmental Protection Agency’s AgSTAR program, of the 317
currently operational biogas systems on farms, there is a wide
diversity of farm sizes using biogas systems. Large farms
aren’t the only ones using them. Specifically:
·
Of the 317
farm-based biogas systems, 265 use dairy manure (84 percent). Of
those:
·
30 farms have
< 500 cows (11 percent)
·
43 have
500-1,000 cows (16 percent)
·
85 have
1,000-3,000 cows (32 percent)
·
55 have
3,000-10,000 cows (20 percent)
·
11 have
10,000+ cows (4 percent)
·
For 41, no
farm size data are currently available (15 percent)
Oppositional Claim 2: Dairies
and other livestock producers are
polluters.
The family dairies of California adhere
to all sorts of national, state, and local regulations, always
aiming to be good stewards and citizens to the environment and
community. These hardworking, well-meaning families have
demonstrated their willingness to improve the environment by
adopting biogas systems to improve upon their existing stewardship.
While any industry sector or population will have individual
outliers, associating the small number of bad actors with poor
stewardship by the vast majority is disingenuous at best and
inflammatory at worst. The overwhelming percentage of farmers meet
all regulations, which are some of the most stringent in the
country, and are not negligent, lawless, or purposeful
polluters.
·
According to
the Innovation Center for U.S. Dairy, the greenhouse gas footprint
of the nation's dairy producers is less than 2 percent of the
nation’s total.19
·
Thanks to
improvements in sustainable farming practices, U.S. dairy farmers
are now using 65 percent less water and 90 percent less land to
produce 60 percent more milk.20
·
Thanks to
improved farming practices, the carbon footprint of producing 1
gallon of milk shrunk by 19 percent between 2007 and 2017,
requiring 30 percent less water and 21 percent less
land.20
·
34 dairy
companies representing 75 percent of U.S. milk production have
voluntarily adopted the U.S. Dairy Stewardship Commitment to help
the U.S. dairy industry collectively advance, track and report
progress on social responsibility areas important to consumers,
customers, and communities.21
·
U.S. dairy is
a diverse, complex sector made up of just under 30,000 farms and
hundreds of dairy companies, with representation across the entire
country.22
·
A 2021 World
Wildlife Fund analysis found that U.S. dairy farms could achieve
net zero emissions in as few as 5 years if the right incentives and
supportive policies are put in place. The investment would mean a
return of $1.9 million or more per farm. If even 10% of dairy
production in the U.S. were to achieve net zero, GHG emissions
could be reduced by more than 100 million
tons.23
·
A team of
Virginia Tech researchers found that the removal of dairy cows from
the U.S. agricultural industry would only reduce greenhouse
emissions by about 0.7 percent — and it would significantly
lower the available supply of essential nutrients for
humans.24
·
Dairy packs a
serious nutrient punch, effectively, efficiently, and affordably
providing the annual protein requirements of 169 million people and
the annual calcium requirements of over three-quarters of the
population.24
·
Dairy
encompasses the six billion people who eat and drink its products
annually, as well as the 600 million people who live and work on
the world’s 133 million dairy farms, and the one billion
people who rely on the dairy sector to support their livelihoods
and communities.25
·
In the U.S.,
there are 280 on-farm anaerobic digester systems used to convert
manure into renewable energy. Of those, 77 percent are located on
dairy farms.26
·
80 percent of
what dairy cows consume cannot be eaten by people, including
by-products of other foods like citrus pulp and almond
hulls.27
Oppositional Claim 3:
Programs designed to help pay for the technologies and practices
that reduce GHG emissions on livestock operations are subsidies and
dairies and other livestock operations should be regulated, not
subsidized.
Dairies and livestock operations are
already some of the most regulated industries in the country. They
are required to meet and maintain compliance with federal, state,
and local regulations at all times. Without the current help from
California programs, many of the family farms across California
would be unable to afford biogas systems and would not be able to
capture and reduce the methane emissions created by their farms.
Those making this charge believe that all animal agriculture is
done at the cost of the environment and the underserved communities
around them. This, however, undercuts the economic value of dairy's
role in a healthy, sustainable diet and its efforts to strengthen
and connect the communities it serves.
Oppositional Claim 4: Dairies
are using biogas systems to grow and pollute.
The dairy industry in California has been
experiencing consolidation for decades due to the inherent
economies of scale in the industry and specifically the necessity
to manage costs associated with meeting regulatory standards, and a
volatile pricing system where the price farms receive for their
milk is often out of their control. The United States Department of
Agriculture Economic Research Service (USDA-ERS) recently published
a comprehensive analysis of this trend towards consolidation. Put
simply, many dairies are getting larger, but this is because larger
operations can have more efficiency in production per cow, which
results in a lower number of total cows per unit of milk produced.
Biogas systems are not the cause of consolidation. Biogas systems
are the best way to lower GHG’s and produce renewable energy
for other sectors of the economy.28
In his testimony during the workshop, Dr.
Aaron Smith from UC Davis compared the value of producing milk to
the value of biogas. Dr. Smith said farmers may consider expanding
their herds in order to produce biogas since his analysis concluded
that biogas may be worth about half as much as milk when LCFS and
renewable identification number (RIN) credits are high. However,
his analysis excluded the fact that the farms only receive a
portion of the revenue generated from a biogas operation. Most
biogas projects are owned and operated in conjunction with
companies that have skilled specialties in biogas production. This
allows the farmer to reduce financial risk and means the revenue to
the farmer is usually much less than Dr. Smith’s analysis
showed.
Oppositional Claim 5: The
emissions reductions from biogas systems are
greenwashing.
Studies have shown that recycling all
organic waste and other biomass could lead to renewable natural gas
(RNG) production at a scale of approximately 20 percent industrial
usage of fossil natural gas and 50 percent of residential use. This
is not an insignificant fraction of the natural gas consumption. In
addition, many gas utilities, like Southern Company, National Grid,
SoCalGas, and others, are implementing plans to aggressively reduce
the amount of gas needed to meet residential and industrial needs.
This means that, in combination with increased efficiency, RNG and
hydrogen, will actually be able to meet even larger percentages of
gas use with renewable gas. Similar to California’s vision
for decarbonization, Europe is embracing a similar vision through
their Renewable Energy Directive, or “RED II”, with a
target of 32 percent renewable energy supply by 2030.
Professor and Cooperative Extension Air
Quality Specialist at the University of California, Davis, Dr.
Frank Mitloehner recently commented in a Clarity and Leadership for
Environmental Awareness and Research at UC Davis article that he is
“...always flabbergasted when [he sees] actual methane
reductions hinted at as ‘greenwashing.’ Digesters have
been one of the most effective tools in curbing carbon emissions
from animal agriculture and even displacing some fossil fuel use in
California.”29
The net benefit of methane capture using
digester systems is clear from a scientific basis, as evidenced in
the carbon intensity (CI) score derived from avoided life cycle GHG
emissions. It is unjustified to infer that leakage compromises this
value proposition at farm-scale installations, while most of the
concern focuses on household-scale digesters and not commercial
installations.30
It is recognized that scientific
characterization of total emissions from dairy digester systems is
neither comprehensive nor do these studies suggest a systemic
problem. One study focused on emissions from UK biogas plants
discussed results from measurements of only ten digester
systems31 with almost half demonstrating emissions rates
that are less than 2 percent of total production. Another study by
the International Energy Association found that cross-comparison
was difficult between different methodologies while acknowledging
that episodic events may compromise measurement of average annual
emissions calculations.32 Meanwhile, this synthesis
study shared results collected using thirteen measurement methods
with an average of 2-3 percent loss versus total
production.
It is likely that implementation of best
practices across the global biogas industry, from development and
routine inspection procedures, may result in leak rates on the
lower end of these studies (<2 percent). Furthermore, high RNG
product commodity values, driven by the RIN and LCFS markets,
encourage operators to adopt best practices with respect to leak
detection and mitigation to maximize throughput.
Oppositional Claim 6: Methane
leakage from the natural gas pipeline system makes the use of
renewable natural gas more harmful than the benefit it
provides.
While it is true that there is leakage in
any industrial processing, including biogas, it is important to
note that studies show this to be within 0-15 percent, with
agricultural biogas facilities on the low end at approximately 2
percent. Also, CARB already incorporates this into their carbon
accounting using GREET analyses.33 More importantly, we
can assume that without biogas systems, the baseline is 100 percent
methane released into the atmosphere. Therefore, it is more
accurate to not criticize a 2 percent loss but applaud a 98 percent
capture and conversion. Furthermore, in generating LCFS credits,
projects must account for any methane venting events which occur
during operations.
According to published data for the
United States, methane emissions from conventional natural gas
distribution mains account for 32 percent of the industry's total
methane emissions. It is believed that cast iron pipelines
contribute the most to these emissions, even though they represent
only 3 percent of the miles of all U.S. distribution mains. These
estimates are based on national methane leak rates from an
EPA-funded study which estimated emissions from all sources in the
U.S. natural gas industry.34
Since 1992 the EPA has gathered over 100
companies to participate in their Natural Gas Star Program, a
voluntary program intended to reduce the amount of methane leakage
from distribution pipe systems. In 1997, because of the Star
Program, the U.S. Environmental Protection Agency EPA released a
report which indicated that a potential increase in natural gas
sales would increase methane output by 0.5 to 1 percent annually.
Using 1992 as their baseline, the EPA estimated that 1.4 percent
(plus or minus 0.5 percent) of all gas that travels through pipes
in the United States was emitted. Overall, of all the methane
released by industry in the United States, 20 percent of methane
comes from the natural gas sector. Landfills contribute the most
with 31 percent.35
In the same report, the EPA stated that
of the methane released by the natural gas industry, 37 percent
comes from "Transmission/Storage", 24 percent comes from
"Distribution" and 27 percent comes from “Production”.
The EPA noted that during summer peak times, emissions were
estimated to the highest. The study, contrary to the more recent
findings by a Greenpeace funded study in Europe, argues that using
estimated emissions from 1992, the natural gas sector emits less
greenhouse gas emissions than coal or oil.36 Currently
it is estimated that 2 percent of total greenhouse gas emissions
come from the country's natural gas industry. In 2006, the natural
gas industry operated over 38,000 miles of natural gas pipelines
that were made of cast iron, the leakiest of all types of gas
piping. In 2009, 4,000 miles of new pipes were laid.37
Further studies of methane gas loss rates
need to be completed to assess the situation globally. Assessing
these loss rates will help reduce methane leaks from natural gas
distribution in the United States.38
Biogas systems are a valuable tool, but not a panacea to
solve all of the problems related to manure management.
Biogas systems are at their heart a
biological means to convert carbon into methane and capture it for
use as a renewable fuel. This process specifically decreases
baseline methane emission into the atmosphere by converting the
methane back into carbon dioxide. Although they store waste, reduce
odor, and make subsequent treatment much easier – the
digester itself is not designed nor functions as a nutrient
treatment system. Anaerobic digesters are an essential part of
livestock manure management systems but are not designed to be
replacements for proper nutrient management.
Digesters rely on biological processes to
break down biological material. Any biological system has inherent
variability, making each digester unique in its operation and
performance. This is influenced by feedstock, weather and of
course, management. Digesters are flow-through components of a
manure management system, linking collection and storage. Too often
people look at them as storage systems only or as complete
treatment systems that solve every problem, neither of which is
true.
Biogas systems prevent the release of
methane from uncovered lagoons and lead to a direct reduction in
GHG. A well-designed biogas system can capture as much as 80
percent of the methane that would be produced from a waste stream
that was maintained at 100 degrees F. Even once cooled down, the
emissions from the digestate are not of significant quantity.
Biogas systems are also highly effective
at reducing odors, via the biological conversion of odor-causing
volatile organic acids to biogas. “Using volatile fatty acids
(VFA) as an indicator, anaerobic digestion exhibited an effective
reduction of dairy manure odor offensiveness." Page et al (2015)
based this conclusion on a laboratory experiment that considered
four specific volatile fatty acid concentrations over time for
manure before and after digestion, and a reduction in total VFA by
86–96 percent.39
Treatment through anaerobic digestion can
reduce the number of pathogens within the manure and therefore
limit the number of pathogens entering the environment. Anaerobic
digestion of manure has a pathogen reducing effect with as much as
95-98 percent of common pathogens eliminated in mesophilic (~ 100
degrees Fahrenheit) digesters. The reduction in pathogens has the
potential to be of benefit for: manure application in impaired
watersheds when trying to manage certain pathogens such as
Mycobacterium paratuberculosis (MAP or Johne’s) or
Salmonella, and when considering a community-based
anaerobic digester where manure from multiple farms is combined,
treated, and AD solids and AD effluent returned to the
farms.40
Partial conversion of organic forms of
macro-nutrients to inorganic forms such as organic-P and organic-N
to inorganic forms such as phosphates and ammonia produces a
product (digestate) that we perceive to be uniquely different than
raw manures, and which hold potential for either equal or improved
nutrient and crop management when managed and applied
correctly.
Biogas systems also play a potential
positive role in improving air quality by reducing the hydrogen
sulfide (H2S) released to air as compared to a non-AD
baseline. While the AD process produces H2S, biogas
systems, with their air permits, practice near total control and
conversion of the H2S to less innocuous
forms.
In addition to the above-mentioned
benefits, biogas systems do not play a role, positive or negative,
in nitrate production and release concerns or phosphate release and
eutrophication concerns.
As evidenced by the Workshop testimony
from Newtrient’s Mark Stoermann, the core biogas system can
serve to produce a differentiated digestate wastewater which can
utilize add-on technologies and assist in more efficiently
operating those add-on technologies for alleviation of nutrient
concerns that are not otherwise in the purview of the AD
process.
In closing, we would like to present some direct quotes and
evidence of global support for biogas system use as a tool to
address the GHG emission problem:
According to the United Nations, UN
Environment Programme (UNEP) and Climate & Clean Air Coalition
(CCAC) “... tackling methane emissions is the most
immediate and cost-effective way to avert climate catastrophe,
while identifying AD as a readily available low-cost technology
that can help reduce these
emissions.”41
The European Union Methane Strategy
highlights control of methane emissions as vital to meeting
continental and global climate goals with the strategy proposing
enhanced and targeted support for acceleration of biogas projects
and biogas markets as major drivers for achieving their
goals.42
The International Energy Agency says that
the case for biogas and biomethane lies at the intersection of two
critical challenges of modern life: dealing with the increasing
amount of organic waste that is produced by modern societies and
economies, and the imperative to reduce global greenhouse gas (GHG)
emissions.43
By turning organic waste into a renewable
energy resource, the production of biogas or biomethane offers a
window into a world in which resources are continuously used and
reused, and one in which rising demand for energy services can be
met while also delivering wider environmental benefits. In
assessing the prospects for “organic growth” of biogas
and biomethane, the International Energy Agency (IEA) notes the
expansive role AD and biogas can play in the transformation of the
global energy system.43
The White House Office of Domestic
Climate Policy, in their report on U.S. methane emissions reduction
action plan, emphasizes the vital role anaerobic digestion, biogas,
and associated markets will play in the reduction plan,
particularly as it relates to the U.S. agricultural industry and
the USDA.44
U.S. EPA flatly states that “AD
[is] a common-sense technology to reduce methane
emissions.”45
And finally, two quotes from Professor
and Cooperative Extension Air Quality Specialist at the University
of California, Davis, Dr. Frank Mitloehner, may be the best way to
end these comments, as ABC cannot emphasize agreement strongly
enough:
“In the race to slow climate
change and reduce California’s methane emissions to 40% below
2013 levels by 2030, transforming methane from manure into biogas
with digesters leads all other
initiatives.”46
“In California, digesters are
REDUCING emissions at an incredibly cost-effective rate. Digesters
have reduced 30% of the GHGs mitigated in the California Climate
Investment initiative with less than 2% of state
funding.”47
The American Biogas Council would like to
thank you for the opportunity to comment and for the excellent work
that CARB is doing in leading the way in reducing the impact of
short-lived climate pollutants for California and the entire
nation.
Sincerely,
Patrick Serfass
Executive Director
American Biogas Council
staff@americanbiogascouncil.org
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