Comment Log Display

COMMENTS ON AB 32 PROPOSED SCOPING PLAN,
SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008

17. Agriculture (p. 66)

• Sierra Club remains extremely disappointed with the Plan’s low
expectations for agriculture. The initial Plan only mentioned 1
potential MMT equivalent of GHG reduction from methane capture at
large dairies while the state’s GHG inventory shows 13 MMT
equivalent of methane emissions from manure management and enteric
fermentation. Agriculture contributes about half of California’s
methane emissions, but is far from contributing its share of
reductions under the current Plan. This is especially serious
considering that conventional models of methane underestimate its
effect. The CEC’s inventory used a GWP of 21, revised upward from
the early figure of only 11. The figure used by CEC lags behind
current science, as the newest figures show a 100-year GWP of 25. 
However, there are major questions around using a 100-year GWP when
CH4 is only resident in the atmosphere for about 8 years. The
20-year GWP, which has currently been upgraded to over 70, would be
more appropriate,. If a 20-year GWP is applied, methane would be
seen to contribute 17% of the state’s greenhouse gas impact rather
than the “official” 2004 figure of 5.7%. If shorter term timeframes
are examined, which match the 8 year residency of methane, then the
role of methane would be much greater. In addition, one NASA
scientist has evidence that methane may be twice as powerful as
IPCC assumes. Thus, methane may represent even more of a threat in
human induced global warming. The flip side is that its short
residence in the atmosphere may also represent a great opportunity
to lower GHGs rapidly. This could be amplified by the fact that,
unlike carbon emissions, the vast majority of anthropogenic methane
emissions can apparently be rapidly absorbed by sinks. Tackling the
global methane problem—compared to CO2— is thus a relatively
rapidly achievable goal, and a state like California could
contribute disproportionate benefits that might have truly global
significance.

•  Studies have shown significant methane emissions from bovine
digestion, which raises the question of whether a carbon tax should
be applied to dairy products, such as beef and milk.

•  In Department of Conservation’s study of greenhouse gas
emissions associated with conversion of agricultural land to urban
uses, both direct and indirect emissions should be considered.
Promoting more compact, efficient, transit-oriented urban
development will not only reduce greenhouse gas emissions from
vehicle travel but also conserve agricultural land by minimizing
conversion to urban use.

• The Plan should reference and encourage CDFA’s development of a
strategic plan for agriculture. Efforts to minimize conversion of
prime farmland will be helped if agricultural enterprises now on
the land maintain profitability and sustainability.

• The Plan should emphasize that linking good land use with local
food systems can reduce transportation-related emissions, provide a
premium for farmers selling locally, and even improve access to
healthier foods.

• State and local governments could increase access to local
foods, for example, by direct investments, incentives and
public-private partnerships to develop needed local foods system
infrastructure.

• Joint action by the Department of Food & Agriculture and CARB
could significantly increase the amount of locally produced food
consumed in the state – thus reducing more emissions from
transportation. CDFA and CARB could work together to track and
measure “food miles traveled” and seek ways to cut distances from
food to producer. Cutting down on transport of agricultural
products from agriculture areas to other parts of the state would
lessen GHG.

• The Plan should address urban agricultural issues, such as:

a) What funding can the state supply to assist municipalities in
supporting urban agriculture?

b) What focus can CARB bring on removing barriers to urban
agriculture? CARB and CDFA could work together to: find useable
land for community gardens, inventories of such land; test for
toxicity; reach out to potential urban gardeners; recast city
regulations in favor of urban orchards, edible landscaping, local
composting, and rooftop gardens; and provide more UC Master
Gardener training and technical assistance?

c) Could CARB facilitate funding of local offices in each
municipality to inventory potentially available state-owned lands
and mobilize local community gardeners and organizers?

• Many studies by California scientists and others throughout the
world have shown how organically grown crops have significantly
lowered GHG emissions, from non-use of nitrate fertilizers,
retention of carbon in soils, and other means.

•  The Plan needs to highlight the greenhouse gas reduction
benefits of organic agriculture. The California Energy Commission
Climate Change Research Conference Sacramento, September 10-13,
2007 has five presentations:
http://www.climatechange.ca.gov/events/2007_conference/presentations/index.html

•  Data from The Rodale Institute’s long-running comparison of
organic and conventional cropping systems confirm that organic
methods are far more effective at removing the greenhouse gas,
carbon dioxide, from the atmosphere and fixing it as beneficial
organic matter in the soil. See Laura Sayre, 2003
http://www.newfarm.org/depts/NFfield_trials/1003/carbonsequest.shtml

-- Another study shows confirmed ecological virtues of organic
farming
www.pnas.org/cgi/reprint/103/12/4522.pdf
http://news-service.stanford.edu/pr/2006/pr-organics-030806.html