Comment Log Display

I have four recommendations for the ARB 2030 Scoping:

1.	Increase the methane reduction goal from 40% to 60% by 2030, 

2.	Include in the economic analysis that improvement in the state’s
carbon pricing system take into account the inevitable enactment of
a federal revenue neutral carbon tax and direct ARB to run
scenarios for how that will best integrate with California’s suite
of climate programs,  

3.	Develop simple models for local soil carbon sequestration goals
and targets in Climate Action Plans, and 

4.	Require that Ventura County’s transportation plan be accountable
to the state’s emissions reduction goals and targets independent of
SCAG.

EXPLANATORY REMARKS:

1.  Increase the methane reduction goal from 40% to 60% by 2030
A meaningful price on methane must match its social cost of $4700
per ton. Refer to the attached discussion paper on methane costs
and pricing. The largest source of uncaptured, unburnt methane is
enteric ruminant digestion in California’s dairy industry, by far
the largest dairy industry in the nation.

As a Public Health Nutritionist I look at the refusal of the diary
industry to reduce its emissions not just in terms of the social
cost and injustice of radiative forcing explained in the attached
discussion paper, but also the chronic disease and inflammation
associated with consumption of dairy products especially by people
with less access to education about the truth of these negative
health impacts. I am also concerned about unbalanced U.S. trade
arrangements favoring export of cow’s milk products that have put
small dairies in poor countries around the world out of business. 

Finally I question subsidies for the dairy industry to manufacture
dry milk and dairy-based ingredients such as casein powder for
global industrial food manufacturing with a high carbon and methane
footprint, displacing low carbon, low methane vegetable based
alternatives that can and should be grown close to where they are
manufactured and consumed.  The California dairy industry wants a
free pass to pollute so that it can continue to profit from an
unjust global food system that undermines food localization and
food security in a warming climate.

Regarding public health impacts, the only people in the U.S. who
can digest lactose are those of northern European descent. People
of Asian, Mexican and African descent have various degrees of
lactose intolerance. People of Mexican descent traditionally obtain
enough dietary calcium from the hydrated calcium hydroxide used to
treat corn to make masa for tortillas and tamales. Mexicans do not
need dairy products as a source of calcium when they follow their
traditional diet. Southern ethnic and Asian traditional diets are
also rich in the minerals that the dairy industry claims they must
get from eating cow’s milk products.

As a former Registered Dietitian I have watched for decades the
compromises by the dietetics profession and the USDA to the
powerful dairy industry. There is now a group of professionals
called Dietitians for Professional Integrity objecting to the
corporate food and dairy industry dictating what constitutes a
healthy diet. The dairy industry’s promotion of the health benefits
of cow’s milk is not based in science. ARB must stop bending to
dairy industry and farm bureau lobbyists threatening to leave the
state if ARB properly internalizes the pollution costs of animal
agriculture. Environmental justice requires in fact that people
with less access to knowledge about truly healthy diets be provided
effective public education programs about the climate and health
benefits from avoiding dairy products. 

Vegetarian and vegan food consumption patterns are trending in
California. The first Cow-Con planned for next month
(http://cow-con.com/) signals growing awareness about the climate
costs of eating animal products. It appears to me that Californians
are very ready to accept a rising cost of ruminant animal and dairy
products to more quickly stop global warming. The market is making
space for continuing innovation of ever more delicious, nutritious,
and inexpensive vegetable protein beverages and non-dairy cheese,
yogurt, and frozen desserts. 

Not only is California the largest dairy producer, but 40 percent
of production is exported to other countries. According to analysis
by the United Nations Conference on Trade and Development in its
2013 publication ‘Wake up before it is too late—make agriculture
truly sustainable now for food security in a warming climate”, it
suggests that trade policies must favor sustainable ecological
agriculture practices on all available land in all regions around
the world. Justice is preeminently about food security and food
security is “preeminently local food complemented by traded goods.”
 

Specifically among a list of policy recommendations, it recommends
that trade agreements include mechanisms to internalize
transportation and other costs to favor local food in every
community with exports focused on specialties and surpluses. It is
immoral for the U.S. to subsidize agricultural commodities like
dairy in order to destroy local dairy production in developing
nations while exempting the dairy industry from emissions reduction
regulation.

Finally, California policy to reduce methane emissions to reverse
the extreme radiative forcing is an obvious way to raise revenue
for investment in EJ communities. Unlike the political atmosphere
at the national level, California can pioneer in setting up
significant new revenues from a price on methane. Polls show that
Californians and a majority of the elected do not require revenue
neutral programs to price pollutants. If state politics requires an
unlikely two-thirds vote for policies that target carbon and
methane pricing revenues for innovation and EJ communities,
revenues can be swapped for income and sales tax reductions using
the British Columbia model until a ballot initiative establishes
the mandate for the kinds of climate investments Californians take
pride in supporting.

In short, some form of aggressive cap and tax program on enteric
methane and all uncaptured, unburnt methane can help meet EJ goals
locally as well as globally on many levels, as well as within the
state in terms of quality of life, sustainability, public health,
and enhanced food security in dairy counties.

2. Take into account an inevitable federal revenue neutral carbon
tax.

While this comment does not represent Citizens’ Climate Lobby
(CCL), it is based on my knowledge of the organization’s progress
among members of Congress. Their systematic strategy and
methodology is based on that of Results that for over 25 years has
achieved its goals for federal anti-poverty legislation. Its
legislative proposal called Carbon Fee and Dividend is very quick
and cheap to set up and has the immediate result of a progressive
economic stimulus. It is called a fee because when the revenues are
distributed 100% into the economy as ‘rebates’ to all households,
conservative economists agree it is not a tax.  

This is a prerequisite element only for Congress and in states with
similar political orientation—NOT California. CCL’s advocacy is
strictly focused on the U.S. Congress that will favor a carbon fee
that is simple, transparent, and easily integrated with all kinds
of state and other national programs for maximum harmonization and
speedy implementation and absolutely must be revenue neutral to
receive a majority of votes. CCL has no position on the best carbon
or methane pricing policy or priorities for any other jurisdiction
in the U.S. 

The economic impacts of a federal Carbon Fee and Dividend system
have been the subject of two studies described in the attached
summary and discussion. The greatest economic benefits go to all
low income, minority and rural households, regardless of where they
live or whether they are citizens or documented workers.  It is
thus a national comprehensive and inclusive platform that comes
close to guaranteeing economic justice while driving the entire
nation off of all fossil fuels. It includes a global price trigger
achieved by a border adjustment provision that only Congress can
exercise, in case any U.S. trading partner does not implement a
comparable price on carbon. 

As summarized in the attached paper, the Pacific Region is forecast
by the REMI study to fare better than any other region of the U.S.
because it already has a lower carbon footprint.  The federal
program will create jobs, increase GDP, real income, and assure a
financial cushion for the poor and minorities during the
transition. These studies suggest where more study is needed so
that ARB can best plan for the state impacts of the federal
program. 

Anticipating the speed of implementation of a federal program is
important. The British Columbia carbon tax was set up in less five
months from being enacted. ARB needs to do begin now to do its own
study to replicate REMI’s forecast of annual reduction in fossil
fuel pollutants from a federal Carbon Fee and Dividend. There is
room for more strategic visioning among EJ leaders to achieve
policies for EJ in a sequential focused campaign that maximizes the
potential synergy between quite different models of state and
federal programs. 

EJ leaders who oppose a federal price on carbon because they want
California to maintain those  revenues for their priority
investments are probably so busy they haven’t kept up with the
horrifying daily news about how our planet is being torn apart by
climate change. There is no room to be cynical or want to bargain
about Congress leading to establish an effective global price on
carbon.
  
Yes, a federal program will eventually decrease state revenues from
California’s carbon credit program (as fossil fuels move faster out
of the economy). However, the enteric methane tax revenues may
immediately bolster funding in the state. A creatively tailored mix
of benefits may best be achieved by a revenue neutral federal
program starting on just carbon with the continuation of a non
revenue neutral state program on carbon and the addition of an
aggressive cap and tax on methane.

3. Support speedy development of local goals and targets for carbon
sequestration. 
We know that to sequester more carbon as well as conserve water and
survive drought and flood, the vast majority of acreage must be
weaned off of chemicals and transitioned to biologically active
soil. Modeling including a new study about to released from Cornell
University shows that, as in the rest of the economy, the
transition is most easily achieved by the comprehensive
foundational driver of averaged trends created by market forces and
not by a smorgasbord of targeted regulatory or trading programs.
Regulatory and targeted programs are best stacked onto a steady
predictable market-driven transition off of fossil fuels. The most
supportive market-based carbon pricing system for farmers is Carbon
Fee and Dividend, a comprehensive steadily rising, staged,
transparent, upstream fee that can scale up carbon farming and
emissions reduction on all farms and landscapes. Those who don’t
take action to reduce the carbon footprint of their products will
slowly, eventually fail. 

My career in public health took a turn when I had an opportunity to
take over an ecologically based pest management company. Over the
past thirty years that I have been marketing biological methods to
conventional farmers, I find generally that farmers, like most
business owners, change practices to save money or make money. Some
farmers change in order to stop polluting soil, air and water, but
those are not the values that guide corporate industrial managers
of most conventional farmland. There is a chemical agriculture
mindset cultivated since the 1950’s by the dominant messaging from
chemical companies that is largely antithetical to biological
agriculture. Biological methods are the prerequisite for truly
game-changing levels of carbon sequestration. 

While a federal revenue neutral carbon tax is a steady driver to
scale up of carbon farming by conventional farms, parallel programs
must be set in motion at the local level to motivate and reward
farmers that respond to the rising price of fossil fuels by
sequestering carbon, not just in perennial crops, but in soil. 
There are currently no guidelines or models for establishing
protocols, baselines, metrics and rewards for higher soil carbon
content. Simplification is the key to rapid mobilization of carbon
sequestration practices that should also help farmers to diversity,
localize, and survive the transition off of fossil fuels. 

To this end I recommend support for development of at least one
four-year pilot project to reward those practicing biological soil
management. Such a program in partnership with a local agricultural
county like Ventura County and a local community college
Agriculture Department like the one that is being re-established at
Ventura Community College can engage under-employed young
professionals who have studied soil ecology and environmental
science. 

The human resources are available to carry out baseline and
performance soil sampling and partner with expert scientists and
local growers to analyze the data and devise a program that
motivates all land managers to participate in the paradigm shift
away from chemical to biological agriculture. The potential for
biologically living soil to hold carbon is well documented and must
be given top priority for the development of simple metrics with
meaningful rewards.

4. Require accountability for emissions reduction in Ventura
County’s transportation sector.

Ventura County ranks in the worst 10 percent of counties nationwide
for most criteria air pollutant emissions and exposures. We have 43
unhealthful air quality days per year for sensitive populations and
7 such days annually for everyone. The main sources are mobile, yet
the VC Transportation Commission has no goals for emissions
reductions. In fact, county leadership is moving in the opposite
direction with a ballot initiative to levy a Transportation Sales
Tax with half of the revenues promised for the widening of highway
101 and state highway 118, primarily with HOV lanes that CalTrans
has confirmed lead to induced traffic and no reduction in
emissions. The VC Transportation Commission refuses to discuss
other ways to reduce traffic congestion that will also improve air
quality and reduce GHG emissions. Apparently this is because the
state does not require that the county set emissions goals and
targets.  

Ventura County is a member of the Southern California Association
of Governments that I am told is an overall high net achiever, at
least on paper, for emissions reduction goals and targets.
Therefore, Ventura County can ride the coattails of the rest of
SCAG and pretend to its citizens that we do not have to make any
changes in how we get around. Reducing GHG emissions is absent from
any policy discussion anywhere in this county. This is partly
because being an oil producing county, Western States Petroleum
Association is actively lobbying public officials and leaders of
thought with talking points like “the moral case for fossil fuels”
and false scare tactics about loss of jobs and tax revenues. 

Unless ARB requires Ventura County to establish independent goals
and targets that match those of the state, the heavy influence of
the oil industry will block leaders from taking responsibility for
supporting the transition away from combustion engines. The ten
cities are largely following the county’s absence of leadership.
Accountability should include a website where everyone can see
Ventura County’s and each city’s goals and progress in emissions
reductions from all sources.

Summary: 

The subsidization of pollution by the state’s dairy industry is not
in the public interest. It is time for ambitious slashing of SLCPs.
Next, it is essential to recognize the potential of Congressional
action and stop discounting it; otherwise the climate is going to
run away in unthinkable destruction and there is nothing ARB can do
to prevent it. Next, cities and counties urgently need a template
for carbon sequestration programs. ARB should try to be at the
table advocating for a succession of federal programs and
encouraging a set of local programs that best integrate or support
what ARB wants to do, beginning with a federal revenue-neutral
Carbon Fee and Dividend followed by systematic rewards for soil
carbon sequestration and county mandates for emissions reductions
from mobile sources, and including maintenance of revenue streams
to fund programs for adaptation, localization and resilience in EJ
communities.