Comment Log Display

The Honorable Liane Randolph, Chair
California Air Resources Board
1001 I Street
Sacramento, CA 95814
 
RE: CARB Response April 2022
 
Dear Chair Randolph:
 
My name is Joe Ayala, General Manager of Wärtsilä
North America Inc. Wärtsilä is a global leader in
innovative technologies and lifecycle solutions for the marine and
energy markets. We emphasize innovation in sustainable technology
and services to help our customers continuously improve their
environmental and economic performance. Our dedicated and
passionate team of 17,000 professionals in more than 200 locations
in 68 countries shape the decarbonization transformation of our
industries across the globe. In 2021, Wärtsilä’s
net sales totaled EUR 4.8 billion. Wärtsilä is listed on
Nasdaq Helsinki.
 
I am writing today in response to the Methane, Dairies and
Livestock, and Renewable Natural Gas in California Workshop
(Workshop) held by the California Air Resources Board (CARB) on
March 29. It was made clear during the Workshop that reducing
methane emissions from dairies and livestock facilities is critical
to California achieving its climate goals. One of the key takeaways
for CARB to ensure reduced methane emissions is for CARB to
continue to incentivize the development of anaerobic digesters on
dairy and livestock facilities as well as support the use of
biomethane from these systems in the Low Carbon Fuel Standard
(LCFS) and other programs. Not only are anaerobic digesters and
related technologies critical to reaching California's climate
goals, but continued support of anaerobic digesters on dairies and
other livestock operations is also required by Senate Bill 1383 (SB
1383) (Lara, 2016) and multiple other laws in
California. 
 
CARB staff presented several times throughout the day on the
structure, requirements and results of the program thus far and
recently released the last version of the CARB “Analysis of
Progress toward Achieving the 2030 Dairy and Livestock Sector
Methane Emissions Target” report. According to this analysis
the 2030 target of SB 1383 will not be met without continued
investment in dairy and livestock sector methane reduction
projects. The data indicate that it will cost an estimated $75
million per year to meet the target if the current split between
the Alternative Manure Management Program (AMMP) and Dairy Digester
Research and Development Program (DDRDP) is maintained. 
 
Throughout the Workshop we heard from commenters and speakers
who were opposed to dairy and livestock biogas and suggested that
California could become carbon neutral, with clean air, clean
water, and provide environmental justice for all Californians
without an impact on the dairy and livestock industries. Most of
these speakers were associated with the Leadership Counsel for
Justice & Accountability and they failed to provide specifics
on how California would be able to achieve its climate goals AND
maintain the economic vitality and productivity of the dairy and
livestock sectors. Rather the commenters and speakers used
generalities to argue against what they consider “factory
farms” and “factory farm gas”.
 
We also heard from several experts working in the biogas
industry and at state and federal agencies working closely with the
biogas industry. Many of them stated that the LCFS program is
working, and with increased support and incentives it will meet the
2030 target of SB 1383 without regulating dairy products and milk,
the number one ranked commodity product produced in the state of
California or effecting the almost $58 billion economy that
California Dairy has created.1 Many of these speakers mentioned
that the only proven technology for significantly reducing
emissions is anaerobic digestion (AD) and that, where possible,
pasture based dairies have already been implemented. They pointed
out that the Intergovernmental Panel on Climate Change (IPCC)
recognizes AD as the leading technology to address climate change.
Dairies have made incredible progress as a sector and AD has been
proven to be the most effective solution available today to solve
many of the climate-related issues in California.  
 
I would like to comment specifically on the following issues
that were raised during the workshop:
 
Dairy opponents have submitted a petition to CARB to exclude
dairy biomethane from the LCFS.  
 
This petition, if accepted, would clearly violate the following
requirements of SB 1383 specific to dairy biomethane:
 
• The requirement
that CARB “develop a pilot financial mechanism to reduce the
economic uncertainty associated with the value of environmental
credits, including credits pursuant to the Low-Carbon Fuel Standard
regulations . . . from dairy-related projects producing low-carbon
transportation fuels.”2    
• The requirement to
adopt a mechanism to provide LCFS credits for 10 years to dairy
biomethane producers that begin production before the adoption of
dairy methane regulations.3    
• The requirement
that the California Energy Commission recommend measures to
increase the production and use of biomethane, with priority going
to “fuels with the greatest greenhouse gas emissions
benefits, including the consideration of carbon intensity and
reduction in short-lived climate
pollutants.”4  
 
Accepting the petition would also violate other California laws
calling for in-state biomethane production, including:
 
• AB 1900 (Gatto,
2012) requires that “the commission shall adopt policies and
programs that promote the in-state production and distribution of
biomethane. The policies and programs shall facilitate the
development of a variety of sources of in-state
biomethane.”5  
• SB 1122 (Rubio,
2012) requires the California Public Utilities Commission (CPUC) to
“encourage gas and electrical corporations to develop and
offer programs and services to facilitate development of in-state
biogas for a broad range of purposes.”6   
• AB 2313 (Williams,
2016) requires the CPUC to “consider options to increase
in-state biomethane production and use.”7  
• SB 840 (Budget,
2016) states that for “California to meet its goals for
reducing emissions of greenhouse gasses and short-lived climate
pollutants, the state must . . . increase the production and
distribution of renewable and low-carbon gas
supplies.”8 
• SB 1383 (Lara,
2016) requires state agencies to “consider and, as
appropriate, adopt policies and incentives to significantly
increase the sustainable production and use of renewable gas,
including biomethane and biogas.”9 SB 1383 also requires the
Commission to “consider additional policies to support the
development and use in the state of renewable gas, including
biomethane and biogas, that reduce short-lived climate pollutants
in the state.”10   
• The requirement
that the CPUC consider “adopting a biomethane procurement
program focused on in-state and delivered
biomethane.”11 
 
Not only would accepting the petition be bad policy if one truly
wants to make progress on reducing carbon emissions, but there is
simply no way to exclude dairy biomethane from the LCFS without
violating the unambiguous language and intent of California state
law. There is also virtually no way to meet the 40 percent methane
reduction target without dairy digesters, which are providing by
far the greatest methane reductions of any programs or investments
to date.12,13 
 
Biogas systems are the number one technological approach to
capturing and utilizing baseline short-lived methane emissions from
wastewater and waste solids while also producing renewable energy
and fuels for additional greenhouse gas (GHG) reductions from
fossil fuel offsets. 
 
According to a December 15, 2021, report “Assessing
California's Climate Policies—Agriculture” published by
the Legislative Analyst's Office (LAO)14, CARB estimates that all
DDRDP projects (including those funded but not yet implemented)
will provide significant GHG reductions totalling 2.1 million
metric tons of carbon dioxide equivalents annually. The estimated
emission reductions for each project will vary based on several
factors, particularly the amount of manure flushed into the
digester and the end use of the biogas captured. CARB12,13
estimates that the program reduces emissions at a state cost of $9
per ton, which is one of the lowest costs per ton estimates among
Greenhouse Gas Reduction Fund (GGRF) programs. (For context,
allowances under the cap and trade program—which puts a price
on each ton of GHG emissions in the state—sold for about $28
per ton at the November 2021 auction.) 
 
In CARB’s methodology, emission reductions for DDRDP
projects come from two major sources. First, estimates include
reductions associated with avoided methane emissions –
specifically, the methane emissions captured by the digester that
otherwise would have been released into the air. According to
information provided by CARB, more than 75 percent of the estimated
emission reductions are from avoided methane, though the amount can
vary depending on the project.
 
Second, estimates include reductions associated with avoided CO2
emissions, which assume that fossil fuels are displaced by the
biogas (and biomethane) produced by a digester. (We note that the
combustion of biogas [and biomethane] produces CO2 emissions, but
these emissions are not included in the state’s GHG inventory
because they are biogenic rather than from fossil fuels.) Given
that most digester projects upgrade biogas to biomethane for
transportation fuel, avoided CO2 emissions for most projects
largely come from the displacement of fossil fuels used in the
transportation sector. The current methodology also includes
avoiding CO2 emissions for projects that displace fossil fuels in
natural gas pipelines and in electricity and heat
generation. 
 
Biogas systems, particularly those on dairy and swine farms,
have played and are playing a critical and primary role in meeting
the State of California and CARB goals related to Short Lived
Climate Pollutants. Biogas systems supply low carbon intensity
renewable transportation fuel to the LCFS program for mandated and
scheduled lowering of carbon footprint of consumed transportation
fuel in the state. For California to meet the targeted and
scheduled methane reduction goals for dairy farms in the state
requires that we utilize the proven and tested technology that AD
offers. 
 
The adoption of biogas systems within the LCFS program, both
in-state and out-state, and their subsequent critical role in
meeting state goals, results from a now proven, LCFS-driven,
economic model. This model has allowed for unprecedented
private/public/farmer partnerships and allows costs/revenues/risks
and viability of project development to be shared. This thriving
ecosystem would not function properly if it could only rely on farm
investments.
 
The ultra-low carbon intensity (CI) within the dairy and swine
biogas sector is real and well-vetted within the national
laboratory-developed Greenhouse Gases, Regulated Emissions, and
Energy Use in Technologies (GREET) model. As such, anyone who
values science must appreciate their role in meeting GHG and
climate goals, and not selectively replace them with non-scientific
reasoning. 
 
The low CI of these projects arises from a combination of
well-to-wheels carbon gains plus the methane offsets from baseline
methane emissions from manure management, storage, and application.
Methane offsets from baseline emissions are a legitimate accounting
practice as baseline, pre-biogas systems emissions exist, and are
largely removed through the installation of the biogas system.
 
The United Nation’s IPCC recognizes the methane reduction
potential from AD as up to 99 percent15, and that, along with other
Waste-to-Energy technologies, if used with appropriate air
emissions technology, can produce clean energy. The IPCC
acknowledges however, that if not used properly they can exacerbate
air quality issues16 and can contribute to fugitive emissions that
may reduce GHG reduction benefits17. Appropriately, in developing
the LCFS regulation, CARB addressed these potential adverse
impacts. Per the LCFS regulation, all projects, including biogas
projects, are required to comply with all laws that pertain to
them, including those associated with air and water quality.
Furthermore, in determining a CI score and having it annually
verified by third party auditors, and approved by CARB, dairy and
swine biogas projects are required to account for any fugitive
emissions that may occur along with the emissions associated with
energy inputs necessary to operate the projects.  
 
Some of the language used by those who want to eliminate dairy
and livestock sector methane reduction projects is purposefully
misleading. 
 
Opposition Claim 1: Dairies and livestock facilities are
“Factory Farms” producing “Factory Farm
Gas”.
 
The continual use of the terms “Factory Farm” and
“Factory Farm Gas” when referring to larger livestock
facilities and the biomethane generated from their AD systems,
purposefully mischaracterizes the true nature of these farms. As
voiced by the California dairy producers during the comment period
of the workshop, the dairies in California, as well as elsewhere in
the U.S., are primarily multiple-generation, family-run businesses
with a long history of ties to their respective communities. They
employ people directly and bring other important jobs, local
spending revenues, and valued nutritional products to those
communities where they are located, the nation and the world. This
can be verified with data from the USDA's National Agricultural
Statistics Service (NASS) 2017 Census of Agriculture, which stated
that 38,007 of 40,336 dairy farms in the United States are family
owned (94.2 percent).18  
 
Texas dairy farmer Sieto Mellema captured the sentiment of many
dairy producers when he said that when he looks out among his 3,000
cows and thousands of acres of crops, he does not see a factory. He
sees a dairy farm that he and his family run with the utmost care
and respect for their animals and their land. “Some people
see our farm and they think it’s too big to be normal, so it
must be a ‘factory,’” he said. “We do tours
here all the time and everyone is astounded with the care we
provide our cows. Even people in a rural town like ours (Dalhart)
are amazed, so I can see someone in a large city having this
mindset. The term factory farm is misleading, but it is just not
understanding farming on the part of people who say that. It hurts
me to the core to hear my farm called that, but all you can do is
educate.”
 
In addition, according to the U.S. Environmental Protection
Agency’s AgSTAR program, of the 317 currently operational
biogas systems on farms, there is a wide diversity of farm sizes
using biogas systems. Large farms aren’t the only ones using
them. Specifically:
 
• Of the 317
farm-based biogas systems, 265 use dairy manure (84 percent). Of
those:
• 30 farms have <
500 cows (11 percent)
• 43 have 500-1,000
cows (16 percent)
• 85 have
1,000-3,000 cows (32 percent)
• 55 have
3,000-10,000 cows (20 percent)
• 11 have 10,000+
cows (4 percent)
• For 41, no farm
size data are currently available (15 percent)
 
Oppositional Claim 2: Dairies and other livestock producers are
polluters.
 
The family dairies of California adhere to all sorts of
national, state, and local regulations, always aiming to be good
stewards and citizens to the environment and community. These
hardworking, well-meaning families have demonstrated their
willingness to improve the environment by adopting biogas systems
to improve upon their existing stewardship. While any industry
sector or population will have individual outliers, associating the
small number of bad actors with poor stewardship by the vast
majority is disingenuous at best and inflammatory at worst. The
overwhelming percentage of farmers meet all regulations, which are
some of the most stringent in the country, and are not negligent,
lawless, or purposeful polluters.
 
• According to the
Innovation Center for U.S. Dairy, the greenhouse gas footprint of
the nation's dairy producers is less than 2 percent of the
nation’s total.19  
• Thanks to
improvements in sustainable farming practices, U.S. dairy farmers
are now using 65 percent less water and 90 percent less land to
produce 60 percent more milk.20 
• Thanks to improved
farming practices, the carbon footprint of producing 1 gallon of
milk shrunk by 19 percent between 2007 and 2017, requiring 30
percent less water and 21 percent less land.20 
• 34 dairy companies
representing 75 percent of U.S. milk production have voluntarily
adopted the U.S. Dairy Stewardship Commitment to help the U.S.
dairy industry collectively advance, track and report progress on
social responsibility areas important to consumers, customers, and
communities.21 
• U.S. dairy is a
diverse, complex sector made up of just under 30,000 farms and
hundreds of dairy companies, with representation across the entire
country.22 
• A 2021 World
Wildlife Fund analysis found that U.S. dairy farms could achieve
net zero emissions in as few as 5 years if the right incentives and
supportive policies are put in place. The investment would mean a
return of $1.9 million or more per farm. If even 10% of dairy
production in the U.S. were to achieve net zero, GHG emissions
could be reduced by more than 100 million tons.23 
• A team of Virginia
Tech researchers found that the removal of dairy cows from the U.S.
agricultural industry would only reduce greenhouse emissions by
about 0.7 percent — and it would significantly lower the
available supply of essential nutrients for humans.24 
• Dairy packs a
serious nutrient punch, effectively, efficiently, and affordably
providing the annual protein requirements of 169 million people and
the annual calcium requirements of over three-quarters of the
population.24 
• Dairy encompasses
the six billion people who eat and drink its products annually, as
well as the 600 million people who live and work on the
world’s 133 million dairy farms, and the one billion people
who rely on the dairy sector to support their livelihoods and
communities.25 
• In the U.S., there
are 280 on-farm anaerobic digester systems used to convert manure
into renewable energy. Of those, 77 percent are located on dairy
farms.26 
• 80 percent of what
dairy cows consume cannot be eaten by people, including by-products
of other foods like citrus pulp and almond hulls.27 
 
Oppositional Claim 3: Programs designed to help pay for the
technologies and practices that reduce GHG emissions on livestock
operations are subsidies and dairies and other livestock operations
should be regulated, not subsidized.
 
Dairies and livestock operations are already some of the most
regulated industries in the country. They are required to meet and
maintain compliance with federal, state, and local regulations at
all times. Without the current help from California programs, many
of the family farms across California would be unable to afford
biogas systems and would not be able to capture and reduce the
methane emissions created by their farms. Those making this charge
believe that all animal agriculture is done at the cost of the
environment and the underserved communities around them. This,
however, undercuts the economic value of dairy's role in a healthy,
sustainable diet and its efforts to strengthen and connect the
communities it serves. 
 
Oppositional Claim 4: Dairies are using biogas systems to grow
and pollute. 
 
The dairy industry in California has been experiencing
consolidation for decades due to the inherent economies of scale in
the industry and specifically the necessity to manage costs
associated with meeting regulatory standards, and a volatile
pricing system where the price farms receive for their milk is
often out of their control. The United States Department of
Agriculture Economic Research Service (USDA-ERS) recently published
a comprehensive analysis of this trend towards consolidation. Put
simply, many dairies are getting larger, but this is because larger
operations can have more efficiency in production per cow, which
results in a lower number of total cows per unit of milk produced.
Biogas systems are not the cause of consolidation. Biogas systems
are the best way to lower GHG’s and produce renewable energy
for other sectors of the economy.28  
 
In his testimony during the workshop, Dr. Aaron Smith from UC
Davis compared the value of producing milk to the value of biogas.
Dr. Smith said farmers may consider expanding their herds in order
to produce biogas since his analysis concluded that biogas may be
worth about half as much as milk when LCFS and renewable
identification number (RIN) credits are high. However, his analysis
excluded the fact that the farms only receive a portion of the
revenue generated from a biogas operation. Most biogas projects are
owned and operated in conjunction with companies that have skilled
specialties in biogas production. This allows the farmer to reduce
financial risk and means the revenue to the farmer is usually much
less than Dr. Smith’s analysis showed. 
 
Oppositional Claim 5: The emissions reductions from biogas
systems are greenwashing.  
 
Studies have shown that recycling all organic waste and other
biomass could lead to renewable natural gas (RNG) production at a
scale of approximately 20 percent industrial usage of fossil
natural gas and 50 percent of residential use. This is not an
insignificant fraction of the natural gas consumption. In addition,
many gas utilities, like Southern Company, National Grid, SoCalGas,
and others, are implementing plans to aggressively reduce the
amount of gas needed to meet residential and industrial needs. This
means that, in combination with increased efficiency, RNG and
hydrogen, will actually be able to meet even larger percentages of
gas use with renewable gas. True decarbonization of the gas grid.
Similar to California’s vision for decarbonization, Europe is
embracing a similar vision through their Renewable Energy
Directive, or “RED II”, with a target of 32 percent
renewable energy supply by 2030.
 
Professor and Cooperative Extension Air Quality Specialist at
the University of California, Davis, Dr. Frank Mitloehner recently
commented in a Clarity and Leadership for Environmental Awareness
and Research at UC Davis article that he is “...always
flabbergasted when [he sees] actual methane reductions hinted at as
‘greenwashing.’ Digesters have been one of the most
effective tools in curbing carbon emissions from animal agriculture
and even displacing some fossil fuel use in
California.”29 
 
The net benefit of methane capture using digester systems is
clear from a scientific basis, as evidenced in the carbon intensity
(CI) score derived from avoided life cycle GHG emissions. It is
unjustified to infer that leakage compromises this value
proposition at farm-scale installations, while most of the concern
focuses on household-scale digesters and not commercial
installations.30  
 
It is recognized that scientific characterization of total
emissions from dairy digester systems is neither comprehensive nor
do these studies suggest a systemic problem. One study focused on
emissions from UK biogas plants discussed results from measurements
of only ten digester systems31 with almost half demonstrating
emissions rates that are less than 2 percent of total production.
Another study by the International Energy Association found that
cross-comparison was difficult between different methodologies
while acknowledging that episodic events may compromise measurement
of average annual emissions calculations.32 Meanwhile, this
synthesis study shared results collected using thirteen measurement
methods with an average of 2-3 percent loss versus total
production. 
 
It is likely that implementation of best practices across the
global biogas industry, from development and routine inspection
procedures, may result in leak rates on the lower end of these
studies (<2 percent). Furthermore, high RNG product commodity
values, driven by the RIN and LCFS markets, encourage operators to
adopt best practices with respect to leak detection and mitigation
to maximize throughput.
 
Oppositional Claim 6: Methane leakage from the natural gas
pipeline system makes the use of renewable natural gas more harmful
than the benefit it provides.
 
While it is true that there is leakage in any industrial
processing, including biogas, it is important to note that studies
show this to be within 0-15 percent, with agricultural biogas
facilities on the low end at approximately 2 percent. Also, CARB
already incorporates this into their carbon accounting using GREET
analyses.33 More importantly, we can assume that without biogas
systems, the baseline is 100 percent methane released into the
atmosphere. Therefore, it is more accurate to not criticize a 2
percent loss but applaud a 98 percent capture and conversion.
Furthermore, in generating LCFS credits, projects must account for
any methane venting events which occur during
operations. 
 
According to published data for the United States, methane
emissions from conventional natural gas distribution mains account
for 32 percent of the industry's total methane emissions. It is
believed that cast iron pipelines contribute the most to these
emissions, even though they represent only 3 percent of the miles
of all U.S. distribution mains. These estimates are based on
national methane leak rates from an EPA-funded study which
estimated emissions from all sources in the U.S. natural gas
industry.34  
 
Since 1992 the EPA has gathered over 100 companies to
participate in their Natural Gas Star Program, a voluntary program
intended to reduce the amount of methane leakage from distribution
pipe systems. In 1997, because of the Star Program, the U.S.
Environmental Protection Agency EPA released a report which
indicated that a potential increase in natural gas sales would
increase methane output by 0.5 to 1 percent annually. Using 1992 as
their baseline, the EPA estimated that 1.4 percent (plus or minus
0.5 percent) of all gas that travels through pipes in the United
States was emitted. Overall, of all the methane released by
industry in the United States, 20 percent of methane comes from the
natural gas sector. Landfills contribute the most with 31
percent.35  
 
In the same report, the EPA stated that of the methane released
by the natural gas industry, 37 percent comes from
"Transmission/Storage", 24 percent comes from "Distribution" and 27
percent comes from production. The EPA noted that during summer
peak times, emissions were estimated to the highest. The study,
contrary to the more recent findings by a Greenpeace funded study
in Europe, argues that using estimated emissions from 1992, the
natural gas sector emits less greenhouse gas emissions than coal or
oil.36 Currently it is estimated that 2 percent of total greenhouse
gas emissions come from the country's natural gas industry. In
2006, the natural gas industry operated over 38,000 miles of
natural gas pipelines that were made of cast iron, the leakiest of
all types of gas piping. In 2009, 4,000 miles of new pipes were
laid.37  
 
Further studies of methane gas loss rates need to be completed
to assess the situation globally. Assessing these loss rates will
help reduce methane leaks from natural gas distribution in the
United States.38  
 
Biogas systems are a valuable tool, but not a panacea to solve
all of the problems related to manure management. 
 
Biogas systems are at their heart a biological means to convert
carbon into methane and capture it for use as a renewable fuel.
This process specifically decreases baseline methane emission into
the atmosphere by converting the methane back into carbon dioxide.
Although they store waste, reduce odor, and make subsequent
treatment much easier – the digester itself is not designed
nor functions as a nutrient treatment system. Anaerobic digesters
are an essential part of livestock manure management systems but
are not designed to be replacements for proper nutrient
management.
 
Digesters rely on biological processes to break down biological
material. Any biological system has inherent variability, making
each digester unique in its operation and performance. This is
influenced by feedstock, weather and of course, management.
Digesters are flow-through components of a manure management
system, linking collection and storage. Too often people look at
them as storage systems only or as complete treatment systems that
solve every problem, neither of which is true.
 
Biogas systems prevent the release of methane from uncovered
lagoons and lead to a direct reduction in GHG. A well-designed
biogas system can capture as much as 80 percent of the methane that
would be produced from a waste stream that was maintained at 100
degrees F. Even once cooled down, the emissions from the digestate
are not of significant quantity. 
 
Biogas systems are also highly effective at reducing odors, via
the biological conversion of odor-causing volatile organic acids to
biogas. “Using volatile fatty acids (VFA) as an indicator,
anaerobic digestion exhibited an effective reduction of dairy
manure odor offensiveness." Page et al (2015) based this conclusion
on a laboratory experiment that considered four specific volatile
fatty acid concentrations over time for manure before and after
digestion, and a reduction in total VFA by 86–96
percent.39  
 
Treatment through anaerobic digestion can reduce the number of
pathogens within the manure and therefore limit the number of
pathogens entering the environment. Anaerobic digestion of manure
has a pathogen reducing effect with as much as 95-98 percent of
common pathogens eliminated in mesophilic (~ 100 degrees
Fahrenheit) digesters. The reduction in pathogens has the potential
to be of benefit for: manure application in impaired watersheds
when trying to manage certain pathogens such as Mycobacterium
paratuberculosis (MAP or Johne’s) or Salmonella, and when
considering a community-based anaerobic digester where manure from
multiple farms is combined, treated, and AD solids and AD effluent
returned to the farms.40 
 
Partial conversion of organic forms of macro-nutrients to
inorganic forms such as organic-P and organic-N to inorganic forms
such as phosphates and ammonia produces a product (digestate) that
we perceive to be uniquely different than raw manures, and which
hold potential for either equal or improved nutrient and crop
management when managed and applied correctly.
 
Biogas systems also play a potential positive role in improving
air quality by reducing the hydrogen sulfide (H2S) released to air
as compared to a non-AD baseline. While the AD process produces
H2S, biogas systems, with their air permits, practice near total
control and conversion of the H2S to less innocuous
forms. 
 
In addition to the above-mentioned benefits, biogas systems do
not play a role, positive or negative, in nitrate production and
release concerns or phosphate release and eutrophication
concerns. 
 
As evidenced by the Workshop testimony from Newtrient’s
Mark Stoermann, the core biogas system can serve to produce a
differentiated digestate wastewater which can utilize add-on
technologies and assist in more efficiently operating those add-on
technologies for alleviation of nutrient concerns that are not
otherwise in the purview of the AD process.
 
In closing, we would like to present some direct quotes and
evidence of global support for biogas system use as a tool to
address the GHG emission problem: 
 
According to the United Nations, UN Environment Programme (UNEP)
and Climate & Clean Air Coalition (CCAC) “... tackling
methane emissions is the most immediate and cost-effective way to
avert climate catastrophe, while identifying AD as a readily
available low-cost technology that can help reduce these
emissions.”41 
 
The European Union Methane Strategy highlights control of
methane emissions as vital to meeting continental and global
climate goals with the strategy proposing enhanced and targeted
support for acceleration of biogas projects and biogas markets as
major drivers for achieving their goals.42 
 
The International Energy Agency says that the case for biogas
and biomethane lies at the intersection of two critical challenges
of modern life: dealing with the increasing amount of organic waste
that is produced by modern societies and economies, and the
imperative to reduce global greenhouse gas (GHG)
emissions.43 
 
By turning organic waste into a renewable energy resource, the
production of biogas or biomethane offers a window into a world in
which resources are continuously used and reused, and one in which
rising demand for energy services can be met while also delivering
wider environmental benefits. In assessing the prospects for
“organic growth” of biogas and biomethane, the
International Energy Agency (IEA) notes the expansive role AD and
biogas can play in the transformation of the global energy
system.43 
 
The White House Office of Domestic Climate Policy, in their
report on U.S. methane emissions reduction action plan, emphasizes
the vital role anaerobic digestion, biogas, and associated markets
will play in the reduction plan, particularly as it relates to the
U.S. agricultural industry and the USDA.44 
 
U.S. EPA flatly states that “AD [is] a common-sense
technology to reduce methane emissions.”45 
 
And finally, two quotes from Professor and Cooperative Extension
Air Quality Specialist at the University of California, Davis, Dr.
Frank Mitloehner, may be the best way to end these comments, as ABC
cannot emphasize agreement strongly enough: 
 
“In the race to slow climate change and reduce
California’s methane emissions to 40% below 2013 levels by
2030, transforming methane from manure into biogas with digesters
leads all other initiatives.”46 
 
“In California, digesters are REDUCING emissions at an
incredibly cost-effective rate. Digesters have reduced 30% of the
GHGs mitigated in the California Climate Investment initiative with
less than 2% of state funding.”47 
 
I would like to thank you for the opportunity to comment and for
the excellent work that CARB is doing in leading the way in
reducing the impact of short-lived climate pollutants for
California and the entire nation.
 
Sincerely,
Joe Ayala
 
 
 
 
Joe Ayala
GM Puregas, North America  
Renewable Gas, North America
 
--- 
Tel +1 281 233 6367
Mob +1 346 277 8312
joe.ayala@wartsila.com
 
--- 
Wärtsilä North America, Inc. 
11710 N. Gessner Rd. Suite A
Houston, Texas 77064
 
 
 
 
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