Comment Log Display

Comments EJAC	8-5-2016
Ron Whitehurst
Pest Control Advisor
Rincon-Vitova Insectaries, Inc.
www.rinconvitova.com
108 Orchard Dr
Ventura, CA 93001

I am a small business owner, working in the area of biological pest
control, with our rearing facility situated in the oil field north
of Ventura.  Half of my business is the production of tiny wasps
that attack houseflies. We are part of a $10-25 million industry
selling biocontrol to animal agriculture and to the equine
industry.  

Methane
We understand the struggles of California’s dairies, but we know
that those who use our products and keep trying to do a better job
of pasture management and less antibiotics can ALSO adopt the
technologies to stop emitting methane into the atmosphere.  I have
seen calculations showing that it will add less than 20% to the
retail price of dairy products, a small price for society to pay
for demonstrating to the world how to stop that source of climate
forcing. Downsizing herds and managing cows to capture the methane
is not a hardship on consumers, because the less polluting
alternative nut, legume, and seed milks are proven to be much
healthier for everyone.   I read an article showing that the Dairy
Cares threat of leakage is based on false assumptions. It is time
to stop letting our state be a leading methane polluter because ARB
can’t stand up to the dairy industry.


While the oil industry pollution risk around my home and business
is a big concern, global warming far outstrips pollution as a
problem of extremely high consequence in my view.  California must
continue to improve its policies to be a world model for faster
emissions reductions. We need your support for a WW II style
mobilization with much more ambitious goals and targets for GHG
emissions and unburnt, uncaptured methane reduction. 2050 is too
long to wait for 80% reductions of GHG emissions and 40% is far too
low a target by 2030 for enteric methane reductions. California can
and must set honest goals and targets commensurate with the scale
of the problem. Otherwise, how can it claim climate leadership?
With climate change tearing our world apart right now, policies
that take us to 2nd or 3rd base are another form of climate denial.
We need state plans that knock this problem out of the park and
drive all the runners home AND we also MUST have a federal price on
carbon to bring all the states along and serve as a trigger for a
predictable, incorruptible, steadily rising global price on carbon.
California business that adapts to the new priorities of GHG
reduction/elimination will be world leaders as the rest of the
world catches up.

Here are my specific recommendations related to my business and
profession that would help create jobs and expand or create new
small businesses similar to mine in rural areas to support the
scaling up of biological agriculture and low-emission dairies.

Carbon Dioxide and Toxic Drift
As an expert in the field of biological pest control, I know that
toxic chemical pesticides are not needed to produce food or manage
landscapes. Promoting biologically intensive agriculture
(regenerative organic) has the following benefits:
	Decrease fossil fuel use (soil has better tilth)
	Decrease NOx from synthetic nitrogen fertilizers
	Increase sequestering of carbon through healthier soil food web
	Decrease toxic pesticide drift
	Decrease particulate material (PM) (from reduced tillage and
better soil tilth)
	Create good clean jobs for the unemployed youth coming out of
college
	Create new professions of Biological Pest Control Scouts, Soil
Carbon Builders and Certifiers, 	and other practitioners needed to
rapidly scale up carbon farming on conventional farms

To do that a simple metric is needed for soil carbon or soil
organic matter SOM – which is part of the standard soil test done
for agriculture. This is needed to set up a meaningful reward
system for carbon farmers who meet an obvious threshold of SOM or
carbon sequestration.  We only need a three-point scale: a lot, a
little, and almost none. Trading is unacceptable, especially when
you admit to the problem that assigning a true cost for methane
threatens to destroy the carbon credit market and we must start
being honest about the social cost of methane!  So, stop trading
carbon credits! Just set the appropriate, comprehensive caps and/or
fees including for uncaptured, unburnt methane. This is the way for
ARB to use the immense potential of biologically intensive
(regenerative organic) agriculture to meet climate action plans
(CAPs) and environmental justice (EJ) while the US Congress
establishes a basic foundational program through a revenue neutral
carbon tax.

Living and working in an oil field, I appreciate regulations on the
volatiles coming from oil wells, pipe lines, dehydration facilities
(DeHy), and other processing sites. I am especially concerned about
benzene, a carcinogen, and hydrogen sulfide, a neurotoxin.
Earthworks did some monitoring of wells in Ojai and Bakersfield and
found disturbing levels of emissions, and negative health effects
on the surrounding communities.
https://www.earthworksaction.org/library/detail/californians_at_risk_full_report#.V6g8-zXKjfY.
The dust in the Ventura oilfield is getting worse and worse. There
is no remedy for that except to make the oil industry pay the true
cost on society of its product.  Contrary to the keynote speaker at
the conference brought to Ventura last year by WSPA, there is no
moral case for fossil fuels.

EVs
Ventura County Transit Commission never talks about emissions
reductions nor about promoting technology. They should be looking
at promoting electric vehicles (EVs) and other zero emission
vehicles instead of widening 101. Being in the SCAG, VCTC thinks it
can ride the coattails of SCAG’s emissions reductions achievements.
Clearly the behavior of VCTC shows that the emissions reductions
goals and targets are too low and that each county must be required
to carry its own weight rather than be averaged with other
counties. Every county must be required to have a technology
development plan for zero emission vehicles and fast-track transit
and alternative transit infrastructure instead of freeway
expansion.

With the millions of gas cars on the road, representing a huge
amount of embedded energy, we should encourage conversions to
electric which would create good middle-income jobs through:
	Electric conversion training programs at high schools, junior
colleges and trade schools.
	Subsidized or no-interest financing for the batteries (the
expensive part of a conversion)
	Classy converted antique and ‘clunker’ car shows with how-to
demos
	Associated solar carport installs where the converted EV’s can be
directly charged.

RV parks require occupants to move out of park for 3-5 days every 6
months. This is a wasteful practice as far as gas consumption is
concerned, and a burden on low income people who use RVs as easy
entry home ownership. Further, solar carports, solar sheds and
solar RV roofs would decrease the carbon footprint of RVs. Solar
roofs also decrease the heat load on the RV, decreasing the energy
required to bring the interior to a comfortable temperature.
Combination solar heat and PV panels on RV roofs or south sides
would reduce fossil fuel use. Of course solar covers for EV
charging are needed at mobile homes parks as well as RV parks.

Small businesses, such as ours need a good zero emissions van or
truck for pick up and delivery. My business needs a small pickup
that can go 85 miles on a charge once a week. If there were a
trustworthy garage and a way to borrow for one of the new longer
lasting batteries, I would do a conversion that would perfectly
meet my needs for the lowest cost.  Many small businesses like ours
have similar specialized transport requirements and I understand
that small businesses employ over 90% of the people in our county
so if ARB helps me do right by the climate in an economical way I
can compensate my employees better.

Yours,

Ron Whitehurst