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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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