Comment Log Display

Western United Dairymen is a statewide dairy farming organization
representing our members on issues of importance in all relevant
venues. Our 1,100 member families produce 60% of the California
milk supply. Our farms are located throughout the length and
breadth of the state, and cover a wide range of geography, size,
and other characteristics. We appreciate the chance to comment on
the Climate Change Draft Scoping Plan.
We believe that the capture of greenhouse gas (specifically
methane from manure) and its conversion to renewable energy
presents an opportunity for our members, and we wish to facilitate
their participation. However, any dairy methane capture program
must be implemented in an appropriate and cost-effective manner.
Please consider the following comments on the Climate Change Draft
Scoping Plan.
General:
The total greenhouse gas (GHC) emissions of California are
presented in sectors and sub-sectors. Graphs and other analyses
are presented without reference back to the total state inventory.
We understand the reasons for this approach, but as presented, the
information can be easily misinterpreted or misquoted. We suggest
that when a sub-sector graph or analysis is presented, information
as to its contribution to the sector and to the state inventory be
prominently included.
Climate Change Draft Scoping Plan, II. Preliminary Recommendation
16. Agriculture:
(1)	Investment in manure digesters is encouraged by the Scoping
Plan. At a recent international dairy summit on climate change it
was recognized that bio-digesters are one of the main measures
that dairy farmers can take to reduce methane emissions. We agree.
However, there was universal agreement that manure digesters cannot
be a part of any climate action plan without a significant
contribution from the public sector for financial and technical
assistance, and there will need to be considerable regulatory
recognition and facilitation. We agree with this conclusion, and
do so from our experience administering the California Dairy Power
Production Program (CDPPP). This fact is important to include in
the Scoping Plan—it is not only a California situation, but
familiar around the world. Implementing a significant dairy
digester program in California, like everywhere else in the world,
will require substantial public investment. 
(2)	Western United Dairymen is unequivocally opposed to any
consideration, at any time and in any manner, to a mandate to
install methane digesters on dairy farms. If digesters are a
requirement of law, any opportunity to acquire carbon credits and
participate in the carbon marketplace will be lost to dairy
producers. We anticipate that the potential revenues generated
from sales of dairy digester carbon credits will be an important
part of improving the financial feasibility of digester
installations. Our experience so far, as related above through our
administration of the CDPPP, has shown that digester installations
have a very difficult time returning competitive financial
performance. Any action to worsen this situation should be
rigorously avoided. Mention of future consideration of a mandate
to install digesters should not appear in the Scoping Report. We
request that it be removed.
(3)	Reference is made to the need for further research regarding
enteric methane emissions. We concur, but this does not show up in
the research section of the Agricultural Appendix.
Appendix C, Chapter 11, Agriculture, Preliminary Recommendations
(A-1):
(1)	The title of this section reads “Methane Capture at Large
Dairies.” Opportunities are not limited to large dairies. We
suggest simply dropping the term “large.”
(2)	Paragraph 1 of (A-1) leads with the statement that the “The
primary driver behind the projected increase in agricultural GHG
emissions is growth in dairy livestock.” While this statement may
be technically correct, i.e. dairy contributes to overall growth
in combined agricultural emissions, as it is currently presented
it tends to lead to the conclusion that the primary source of
agricultural GHG is dairy manure, which we do not understand to be
true. Our understanding specifically is that while dairy is the
primary source for methane from manure in California, it is not
true for total GHGs. Our understanding is that the major manure
contribution is in the form of N2O from pastoral sources, and that
pastoral enteric methane is also significant. While we agree that
there is little growth in pastoral emissions from all classes of
livestock, clarification in this section is necessary so that it
is not misleading. Limiting dairy manure methane will not
eliminate livestock GHG emissions, nor will it be sufficient to
offset emissions from other agricultural sources.
(3)	Paragraph 2 of (A-1) identifies that biogas can be flared,
burned in a turbine, or cleaned for natural gas use. No mention of
utilization in an internal combustion engine is made. This should
be corrected, since as new IC engines are developed, their use is
likely to remain valid for biogas. This will be in a stationary
situation such as generator sets and water pumping, or as you
mention in the case of landfill gas, as a vehicle fuel.
Furthermore, other technologies for the efficient and cost
effective uses of dairy digester gas have so far proven to be
unsustainable. Fuel cells and microturbines appear to have
potential in dairy biogas applications but much work is necessary
to adapt these technologies for reliable operation. Pipeline
injection is receiving a lot of attention and has certain
advantages; however, it is not only a very expensive alternative,
but is limited to those dairy facilities located near a utility
pipeline. Additionally, reliable and sustainable performance for
gas cleanup and compression has yet to be demonstrated in a dairy
environment. Acceptable gas standards must be met before injection
will be allowed. These issues are valid considerations that must be
addressed if the carbon reductions expressed in the Scoping Plan
are to be realized. As we mention below, barriers—be they
technical, regulatory, financial, or physical—that might be
expected to impede implementation of dairy digester technology
should be a prominent part of the Scoping Plan discussion.
(4)	Paragraph 3 of (A-1) states “…dairies will provide early
voluntary emissions reductions….” No mention of the unresolved
regulatory barriers that currently exist and that are impeding the
continued development of this opportunity are presented until later
in Paragraph 4, and even then it is somewhat buried in the text. In
order to be complete, any report or scoping document must emphasize
the kinds of difficulties encountered regarding potential adoption
and utilization of any technology, including digester gas
technologies. To fail to prominently display the roadblocks
simultaneously with the presentation of potential opportunities
will give a faulty assessment of the relevance of the technology
and an inaccurate picture of the reductions available, and it may
lead to misdirection of future courses of action. 
Appendix C, Chapter 11, Agriculture, Areas of
Research/Opportunities for Future GHG Emission Reductions,
Efficiency Improvements:
(1)	We appreciate and concur with the presentation of efficiency
of agricultural operations as a sound strategy to accomplish GHG
reductions. This is especially true for the dairy industry. Our
forthcoming discussions should focus on emissions per unit of milk
production, not on a per cow basis.
(2)	We were surprised to note that efficiency in milk production
was not identified as a research need. We believe that additional
work needs to be supported in this area to quantify and inventory
reductions from California-specific dairy efficiencies, especially
in the areas of enteric emissions and reproduction. California
dairy farms have already accomplished per unit production
efficiencies far beyond what we find in other countries and other
states. This contribution should be recognized in the Scoping
Plan. Comparative information of dairy farming internationally is
available from the International Farm Comparison Network, located
in Germany. The contact is Torsten Hemme at
torsten.hemme@ifcndairy.org.
Western United Dairymen thanks you for the opportunity to comment
on the Climate Change Draft Scoping Plan. We know that our
suggestions will be seriously considered. Please feel free to
contact us if you wish further discussion.