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Comment 27 for Public Input on Cap-and-Trade Auction Proceeds Second Investment Plan (investplan2-ws) - 1st Workshop.
First Name: Albert
Last Name: Straus
Email Address: albert@strausmilk.com
Affiliation:
Subject: Short Lived Climate Pollutants and Daries- Straus Family Creamery
Comment:
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
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