Comment Log Display

Public Comment for CARB's LCFS Program				                         
1/7/22

Expanding LCFS to Support California Agriculture: Putting waste
biomass to work for food security, air quality, job creation, and
climate risk reduction

California currently produces an annual flow of more than 50
million metric tons (MMT) of waste biomass per year, the volume of
which is rapidly accelerating because of efforts to contain the
state's wildfire emergency. Farm and food processing waste comprise
over one quarter of this material, and like other biomass it
presents a substantial challenge to the state's greenhouse gas
(GHG) mitigation goals. Burning agricultural waste has recently
been banned because of this and public health risks but hauling
this material to landfill merely displaces waste storage capacity
while deferring emissions to decomposition. It has long been
understood that recycling this material can improve soil
productivity, but the traditional methods for this, direct mulching
and composting, are relatively inefficient and emission-intensive,
requiring storage capacity and contributing significantly to the
20% of global GHG emissions attributable to agriculture.

Figure 1: Green Energy from Agricultural Waste
 

As a leading state initiative for decarbonization, LCFS is too
limited in scope. Transport fuels are not the only significant
biogenic pathway to displace fossil fuel use and its attendant
environmental damage. Thanks to modern bioenergy science and
technology, alternatives exist that can largely transform this
waste biomass, converting it into biofuels, agrochemicals, and soil
amendments that substantially reduce agriculture's carbon footprint
while robustly enhancing soil productivity, food security, and
rural livelihoods. The primary agrochemical output of this process
(Figure 1) is green fertilizer produced from biogas. This biogenic
chemical has the same productivity benefits as conventional
fertilizer, but it also displaces the fossil fuels usually required
to produce conventional synthetic fertilizer. Beyond this
innovation, other valuable products and services of this biomass
conversion include waste reduction, biochar for soil amendment and
carbon sequestration, and a variety of other green energy services
illustrated in the flowchart. Compared to composting, which
directly releases highly radiative methane emissions and also
presents health and sanitation risks (including rodents, other
vermin, and an array of pathogenic microorganisms), gasification
re-forms biogenic carbon into fossil fuel substitutes. While green
fertilizer improves soil productivity and agrifood sustainability,
it also displaces natural gas. Likewise, biodiesel and biogasoline
can displace liquid fossil fuels in farm mechanization, vehicles,
heating, and electric power. 

Using modern mobile gasification technologies (e.g.
https://cariboubiofuels.com/) to process biomass at or near
individual farms, all these benefits can be integrated into farm
operations, saving money on inputs, adding value, and conferring
economic and environmental benefits across rural communities, some
of the most disadvantaged in the state.. In addition to the direct
values of soil productivity and clean energy services, farms reduce
their costs for (and emissions from) conventional energy and
agrochemicals. We argue that these bioenergy conversion pathways
should be recognized by CARB with LCFS carbon credit certification
like livestock waste management is today. Expanding LCFS for
biomass conversion would provide additional livelihood benefits to
farmers and stimulate further green innovation across California.
State-of-the-art biomass conversion can be a potent catalyst for
progress, enabling agriculture, forestry, and municipal solid waste
management to take fuller partnership in the Golden State's quest
for sustained and inclusive prosperity.

Thank you for your consideration.

Respectfully,
David Roland-Holst, PhD
Managing Director, Berkeley Economic Advising and Research
Adjunct Professor, Department of Agricultural and Resource
Economics, UC Berkeley
dwrh@berkeley.edu 
510-421-0365