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Dear Sir or Madam: 

I am employed by the California Air Pollution Control Officers
Association (CAPCOA) as the administrator of the CAPCOA Greenhouse
Gas Reduction Exchange (GHG Rx).  The GHG Rx is a registry and
information exchange for GHG emission reduction credits designed
specifically to benefit the State of California   It is a low cost,
secure online platform for exchange of locally-generated GHG
credits derived from California-only voluntary projects based on
Board-approved protocols.  The GHG Rx is implemented by
Participating Air Districts throughout the state.  Credits must be
real, quantified, verified, permanent, enforceable,
additional/surplus to be accepted within the GHG Rx.  There are
several co-benefits that can be realized through use of the GHG Rx:
financial resources invested in-state will help create local jobs
and result in other needed air pollution co-benefits as well as
socioeconomic and other environmental co-benefits from projects in
California.  

The GHG Rx has several CAPCOA Board approved protocols, including,
among others, two Biogas Control Systems (BCS) protocols: 1)
Organic Waste Digesters (OWD) – Livestock Manure and 2)
Livestock – Dairy Cattle & Swine.  Of our Participating Districts,
the San Joaquin Valley APCD and others have significant farming and
ranching operations within their respective jurisdictions.  

I suggest that use of CAPCOA GHG Rx be recommended as an option to
utilize for the mitigation program and specifically for biodigester
(OWD) projects.  The program meets all the criteria listed within
the document and would satisfy many (or all) of the additional
considerations.  Additionally, I respectfully suggest that the Air
Resources Board provide specific recommendations as to the funding
subsidies (amount and type) that should be provided by Southern
California Gas to support OWD projects.  At this time, State
funding available through the Treasurer’s Office would not be
workable for such projects.  There are limited USDA grants and loan
funding, however they are insufficient to encourage widespread use
of OWD.  Given the magnitude of the methane emissions in the State
from agriculture, and that they are primarily associated with
enteric fermentation and emissions from dairy manure lagoons, it is
critical that 1) mitigation is conducted, and, 2) that significant
subsidies (grants/low-cost loans and guarantees) are provided
through the Aliso Canyon program that would be applicable to a
broad array of livestock operations, large and small.  

Thank you for your consideration.   

Barbara Coler, Coler Environmental Consulting LLC