Comment Log Display

Dear Chair Randolph:
 
As the voice of the United States biogas
industry, we are 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. The American Biogas Council (ABC) represents
more than 300 and 3,000 professionals throughout the biogas supply
chain that are dedicated to recycling organic waste into biogas and
soil products. 
 
The ABC applauds CARB on presenting a
virtual Workshop that was attended by over 800 people and provided
an opportunity for a balanced discussion of the issues around the
California Low Carbon Fuel Standard (LCFS) and SB 1383 regulations
as they relate to the dairy and livestock industries. 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 keyways 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. 
 
Sincerely,
Patrick Serfass
Executive Director 
American Biogas Council
staff@americanbiogascouncil.org