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Comment 66 for Short-Lived Climate Pollutant Draft Strategy (slcpdraftstrategy-ws) - 1st Workshop.
First Name: Todd
Last Name: Shuman
Email Address: tshublu@yahoo.com
Affiliation: Analyst, Wasteful UnReasonable Use
Subject: Supplemental comments concerning CA ARB and SLCP Reduction Strategy
Comment:
These comments below supplement my previous oral and written comments that I have submitted con-cerning this process. What follows are my written comments based largely on my testimony at the CA ARB SLCP Reduction Draft Strategy, based upon oral comments submitted on October 14, 2015 in Diamond Bar, CA at the CA ARB SLCP Reduction Strategy Workshop. 1: CA ARB needs to align its methane GWP policy across all CA ARB policy spheres with recent leg-islative and executive recognition of the importance of considering 20-year interval methane GWP constants in evaluating methane’s atmospheric heat-trapping impacts. This recognition has been recently enshrined into California state law, in AB 1496, Section 1(a). 2: Please specify in the EA very specifically why CA ARB is not, will not, and/or cannot use a 2013 IPCC (AR 5th) 20-yr interval methane GWP when preparing CA ARB-related GHG inventories and calculating other CO2 equivalencies related to other CA ARB programs (cap and trade, offsets, pollution permits, proposed ACR offset protocols, etc). 3: I request that CA ARB prepare and present an alternative statewide GHG inventory utilizing 2013 IPCC (AR5th) 10-year interval and 20-yr interval methane GWP constants side-by-side with a statewide GHG inventory utilizing the 2007 IPCC 100-yr methane GWP constant currently used by CA ARB. 4: Specify in the EA what barriers exist to incorporating enteric emissions from livestock into CA ARB programs (such as cap and trade), and why enteric emissions are not already incorporated into these programs. 5: The cap and trade program should include enteric emissions from dispersed livestock as a source of methane emission that must be significantly and rapidly reduced. Ranchers and smaller dairy owners who produce livestock in relatively dispersed locations should be required to purchase pollution permits and offset credits just like any other GHG emitter. 6: CA ARB should enact significant mandatory annual reduction targets for methane emissions associ-ated with anaerobic manure lagoons and enteric emissions. 7: The annual methane emission reduction targets specified in the Draft Strategy for dairy manure should also be applied to enteric emissions (20 percent by 2020, 50 percent by 2025, and 75 percent by 2030), though these targets should be mandatory for both dairy manure and enteric fermentation. I recommend increasing the reduction target from 20 percent to 25 percent for yr 2020. I feel strongly that the CA ARB proposed annual emission reduction of only 5 methane-related MMTCO2e for dairy and livestock enteric fermentation (Table 6, page 43) by 2030 is embarrassingly low and ethically unacceptable. 8: Reliance upon weak, voluntary dairy industry methane reduction targets is grossly inadequate and ethically irresponsible, given the speed and scale with which global warming impacts are manifesting themselves. CA ARB needs to lead, not follow, concerning the matter of enteric emissions. CA ARB should be prodding the industry to fund necessary independent research in order to enable compliance with mandatory annual methane reduction targets of 25 percent by 2020, 50 percent by 2025 and 75 percent by 2030. 9: CA ARB should require the dairy and livestock industry to fund further independent research that explores the viability of methane gas bio-filtration/bioreactors at dairy and beef-product CAFOs, as well as feed/drink-accessible cow methane respirators. CA ARB should also require that independent research into other significant methane-reduction strategies be funded at significant levels by private industry. No public funding should be used for any of this research. No further Greenhouse Gas Reduction Fund (GGRF) resources should be allocated to subsidizing the dairy and livestock industries in any manner, due to the intrinsically anti-social and anti-ecological methane-emission-related consequences of these industries. 10: CA ARB should modify any American Carbon Registry offset protocols currently in use and up for consideration to incorporate either an updated 10-year interval or 20-year interval methane GWP constant. ACR protocols retain a very low, outdated 100-year interval methane GWP constant to preserve carbon credit fungibility over a 100-year period. It is irresponsible for CA ARB to concur with such narrow economic logic in the face of the disturbing climate change-related effects increasingly appear-ing on our rapidly-warming planet. 11: Mandatory carbon credit insurance should also be incorporated into the cost of any carbon offset credit sold to enable new scientific information to be rapidly reflected in updated and revised SLCP GWP constants. 11: Claims made by previous commenters concerning the methane-related emission of grass-fed versus grain-fed livestock are questionable. Various claims and the research supporting such claims conflict within the scientific literature. It is not clear that enteric emissions from livestock on pasture are less than livestock enteric emissions from livestock in CAFOs. Moreover, claims concerning the value of pasture-based dairy operation concerning soil carbon sequestration are especially questionable. Typi-cally, the effective GHG impact of enteric emissions occurring on such operations have been discounted in the most frequently-cited studies by ignoring enteric emissions altogether or through the use of very low and outdated methane GWPs in the GHG-balancing methodologies of such studies. Nonetheless, methane emissions from pasture-based operations will be less overall relative to CAFO dairy operations due to much smaller manure-related methane emissions and the smaller numbers of livestock that are typically involved. In this light, I concur with the C4RP&E June 10, 2015 comment: “Pasture-based systems stock fewer cows per acre than confinement systems, which reduces enteric emissions. ‘The amount of methane emitted by animals is directly related to the number of animals, so that a more intensive farm will have higher emissions…’” Pasture-based dairy systems that involve low manure-related methane emissions and low numbers of livestock relative to current CAFO dairy sys-tems are superior in terms of SLCP reduction value. In addition, water usage devoted to livestock and dairy production would also likely decline if pasture-based dairy systems become ascendant economally and the overall numbers of livestock in pasture-based systems remain cumulatively and substantially lower than in CAFO-based dairy systems. Regardless, all livestock producers need to be treated like the operators of coal-fired electricity genera-tion providers -- they need to be prodded into stopping the externalization of their private production-related environmental costs onto the broader societies and natural ecosystems on this planet. Methane polluters should be taxed or fined for the methane pollution they generate, with the tax or fine based upon a methane-into-CO2-equivalency conversion algorithm that incorporates a 10-year interval me-thane GWP (at best) or a 20-year interval methane GWP (at worst). Sincerely, Todd Shuman, Senior Analyst, Wasteful UnReasonable Use (WURU), Camarillo, CA 805.987.8203, tshublu@yahoo.com
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Date and Time Comment Was Submitted: 2015-10-30 10:31:14
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