Comment Log Display

To CA ARB,

On behalf of Wasteful Unreasonable Use (WURU), I request that CA
ARB use a yr2013 Intergovernmental Panel on Climate Change (IPCC)
20-year interval methane Global Warming Potential (GWP) constant
for all of its methane-to-CO2 equivalency conversion calculations,
as well as require the use of the most current IPCC 20-year
interval methane GWP constant in all of its various programs (cap
and trade [c&t], compliance offsets under c&t, greenhouse gas [GHG]
inventories, existing compliance offset protocols under c&t, future
compliance offset protocols that have been proposed for
incorporation into c&t, pollution permits, etc.)
 

I request that CA ARB institute mandatory annual dairy manure and
enteric fermentation methane emissions reduction targets of 25% by
2020, 50% by 2025, and 75% by 2030.
 
I make such requests for the following reasons: the IPCC (5th,
2013) concludes that at the 10-year timescale, the current global
release of methane from all anthropogenic sources exceeds
(slightly) all anthropogenic carbon dioxide emissions as an agent
of global warming; that is, methane emissions are as significant as
carbon dioxide emissions in driving the current rate of global
warming. At the 20-year timescale, total global emissions of
methane are equivalent to over 80% of global carbon dioxide
emissions. (At the 100-year timescale, current global methane
emissions are equivalent to slightly less than 30% of carbon
dioxide emission.)

 
[Source: Intergovernmental Panel on Climate Change, Climate Change
2013: The Physical Science Basis, page 719, Figure 8.32,
https://www.ipcc.ch/report/ar5/wg1/]

Because of the above information, all anthropogenic sources of
methane emission need to be dramatically reduced as quickly as
possible in order to decelerate further short-term global warming.
Continued rapid global warming could trigger the onset of positive
climate change feedbacks that might dramatically accelerate the
warming of our planet. Since the two biggest sources of
anthropogenic methane emissions in California are enteric
fermentation occurring within the stomachs of livestock and
anaerobic dairy manure lagoons, these two sources need to be
strictly regulated under mandatory emission reduction provisions in
the near future. 
 
Sincerely,

Todd Shuman, Senior Analyst, Wasteful Unreasonable Use,
2260 Camilar Dr, Camarillo, CA 93010, 805.987.8203, 
tshublu@yahoo.com