Comment Log Display

Agricultural Waste Solutions, Inc. (“AWS”), headquartered in
Westlake Village, California, wishes to express our gratitude to
CARB for allowing us the opportunity to present comments on the
Dairy and Livestock Subgroup #1 Meeting of July 17, 2017 and for
inviting comments from stakeholders and the public. AWS works with
California dairy farms to produce low carbon transportation fuels
and carbon negative co-products that reduce GHG emissions and
improve water quality while creating new profit centers from manure
and other ag resources.

Please see below our comments from the July 17, 2017 Dairy and
Livestock Subgroup #1 Kickoff Meeting

• Based on the pie chart included in the presentation on July 17th,
dairy manure accounts for 25% of total methane emissions in
California. The methane emissions created from dairy manure are
created mostly from the lagoons and other storage and handling
practices where manure is purposely allowed to anaerobically decay.
Although lagoons account for most methane emissions from dairy
farms, methane and other SLCP’s are also created during the
anaerobic decaying processes of solids storage, handling and
transportation, composting, and land application. We believe the
state needs to enable and support technologies that process raw
manure, AD digestate and other manure co-products at their freshest
state – before they have had the opportunity to anaerobically decay
and create methane and other SLCPs. Pyrolysis/gasification, when
used in conjunction with AD as a stand-alone solution with fresh
manure feedstock, is a proven technique to prevent methane from
ever forming due to anaerobic decay of manure. Biochar, as a
co-product of pyrolysis, is a carbon negative soil amendment that
will further reduce GHGe from dairy farms. We believe that the
prevention of open anaerobic decay of manure and manure digestate
co-products is the only reasonable method of reaching the 40%
methane reduction mandate from dairies.

• More research incentives are needed to recognize and qualify
non-digester technologies for the reduction of SLCP’s that have a
more holistic approach encompassing all environmental needs and
benefits. Water quality goals associated with individual dairy
nutrient management plans are an example of this. These goals
increasingly cannot be met with AD alone unless the suspended and
dissolved solids (e.g. salts) are kept out of the lagoons and
converted into inert, carbon negative co-products that can be
either be used on the farm as soil amendments or exported off the
farm in a dramatically reduced volume. The lagoon then becomes a
fertigation or clean water reservoir instead of the most
significant methane generator on the farm, allowing farmers to meet
their water quality and nutrient management goals as well as their
methane emission reduction goals. 

• Evaluation metrics and models should be based on GHGe and overall
environmental benefits that include the environmental implications
of long-term practices. The models and metrics needs to be
developed and implemented in advance of the technologies being
included as approved technologies or techniques based on their
abilities to reduce total GHGe from dairies by a greater percentage
than AD and other approved technologies and techniques. An example
of this is the “Pyrolysis/Gasification” category that was recently
added to the CDFA list of AMMP technologies and practices. Although
we fully support the addition of Pyrolysis/Gasification as an AMMP
technology, we recently learned that it will not be accepted as a
2017 CDFA DDRDP AMMP grant program application because there exists
no CA Greet or other evaluation metric and model to evaluate its
overall ability to reduce GHGe from dairy farms. We were told that
such models will need to be generated and approved by CARB, so we
respectfully request that this work begin as soon as possible. 

Respectfully,

Steve McCorkle,CEO
Ag Waste Solutions(AWS)