Comment Log Display

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