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Comment 12 for Design Comments for the GHG Scoping Plan (sp-design-ws) - 1st Workshop.
First Name: Philip
Last Name: Erro
Email Address: philiperro@sbcglobal.net
Affiliation: Westside Resource Conservation District
Subject: Use of Carbon Fees and Mandated REC payments
Comment:
1) First, in section 16. Agriculture of the Preliminary Rcommendation, the discussion is primarily about dairy manure emissions and digestion. There is a brief mention of N20 emissions from fertilizers; ammonia and other pollutants are also emitted from commerical fertilizers. All these emissions can be reduced by building up carbon in the soil, because high carbon soils retain nutrients effectively and thereby diminish the need for artificial fertilizers. Similarly, high carbon soils nourish crops and decrease their vulnerability to pests, reducing the need for pesticides. Since WWII we farmers have increasingly relied on artifical fertilizers and pesticides to get each crop to maturity. But building soil carbon could reduce that reliance and the attendant fertilizer and pesticide emissions such as VOCs. Besides building soil carbon, Integrated Pest Management uses biological as well as chemical means to control pests; and modern sprayers use optical sensors to turn the spray on and off and only spray where the target plants are located. These and other means minimize the use of pesticides on well managed farms. Both the California Department of Food and Agriculture and USDA Natural Resource Conservation Service can provide the ARB information on best practices to minimize air pollution. The ARB should consider awarding carbon fee revenues to farmers sho use these practices. The Agriculture section of the Preliminary Recommendation should also include a discussion of a range of renewable energy opportunities in the agricultural sector. Every 150 acres of trees or vines, where insolation is sufficient, could have a 30 kW solar PV generator. Produce coolers could use parabolic troughs on their roofs to feed absorption chilling; tomato processors could get heat and electricity from concentrated solar technology, as could cattle feedlots. Gasification of almond,walnut, and pistachio prunings could make hullers self-sufficient in electricity, heat, and possibly diesel fuel. Digestion of agricultural waste such as pistachio hulls can produce biomethane. With these and other technologies, California's agricultural sector can produce huge quantities of renewable energy without growing crops to do so. 2) A good use of carbon fee revenues would be to reward farmers for building soil carbon. Conservation tillage(CT) keeps root mass and some crop residue carbon in the soil, whereas conventional tillage opens the soil and releases CO2 to the atmosphere. Because CT reduces the number of tractor operations, diesel fuel is saved, reducing diesel emissions. Carbon build up in the soil also increases moisture retention and decreases the need for irrigation, but this benefit requires four to five years of CT to take effect. Hence there is a lag in water savings and crop yields as carbon content in the soil builds. The cost of more powerful tractors and new implements to transition to conservation tillage is another barrier to adopting CT. An ARB incentive to adopt conservation tillage would help reduce diesel emissions, fertilizer and pesticide emissions, emissions associated with pumping water, and would help sequester carbon. 3) I would like to see the Scoping Plan require that IOU power companies pay Renewable Energy Credits of $0.05 per kWh to fulfill their Renewable Portfolio Standard obligations to farmers who produce on-farm renewable energy.
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Date and Time Comment Was Submitted: 2008-07-15 16:25:05
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