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Comment 66 for Short-Lived Climate Pollutant Draft Strategy (slcpdraftstrategy-ws) - 1st Workshop.


First Name: Todd
Last Name: Shuman
Email Address: tshublu@yahoo.com
Affiliation: Analyst, Wasteful UnReasonable Use

Subject: Supplemental comments concerning CA ARB and SLCP Reduction Strategy
Comment:

These comments below supplement my previous oral and written
comments that I have submitted con-cerning this process. What
follows are my written comments based largely on my testimony at
the CA ARB SLCP Reduction Draft Strategy, based upon oral comments
submitted on October 14, 2015 in Diamond Bar, CA at the CA ARB SLCP
Reduction Strategy Workshop. 
   
1: CA ARB needs to align its methane GWP policy across all CA ARB
policy spheres with recent leg-islative and executive recognition
of the importance of considering 20-year interval methane GWP
constants in evaluating methane’s atmospheric heat-trapping
impacts. This recognition has been recently enshrined into
California state law, in AB 1496, Section 1(a).


2: Please specify in the EA very specifically why CA ARB is not,
will not, and/or cannot use a  2013 IPCC (AR 5th) 20-yr interval
methane GWP when preparing CA ARB-related GHG inventories and
calculating other CO2 equivalencies related to other CA ARB
programs (cap and trade, offsets, pollution permits, proposed ACR
offset protocols, etc).




3: I request that CA ARB prepare and present an alternative
statewide GHG inventory utilizing 2013 IPCC (AR5th) 10-year
interval and 20-yr interval methane GWP constants side-by-side with
a statewide GHG inventory utilizing the 2007 IPCC 100-yr methane
GWP constant currently used by CA ARB.

4: Specify in the EA what barriers exist to incorporating enteric
emissions from livestock into CA ARB programs (such as cap and
trade), and why enteric emissions are not already incorporated into
these programs.

5: The cap and trade program should include enteric emissions from
dispersed livestock as a source of methane emission that must be
significantly and rapidly reduced. Ranchers and smaller dairy
owners who produce livestock in relatively dispersed locations
should be required to purchase pollution permits and offset credits
just like any other GHG emitter.


6: CA ARB should enact significant mandatory annual reduction
targets for methane emissions associ-ated with anaerobic manure
lagoons and enteric emissions. 


7: The annual methane emission reduction targets specified in the
Draft Strategy for dairy manure should also be applied to enteric
emissions (20 percent by 2020, 50 percent by 2025, and 75 percent
by 2030), though these targets should be mandatory for both dairy
manure and enteric fermentation.  I recommend increasing the
reduction target from 20 percent to 25 percent for yr 2020. I feel
strongly that the CA ARB proposed annual emission reduction of only
5 methane-related MMTCO2e for dairy and livestock enteric
fermentation (Table 6, page 43) by 2030 is embarrassingly low and
ethically unacceptable.


8: Reliance upon weak, voluntary dairy industry methane reduction
targets is grossly inadequate and ethically irresponsible, given
the speed and scale with which global warming impacts are
manifesting themselves. CA ARB needs to lead, not follow,
concerning the matter of enteric emissions. CA ARB should be
prodding the industry to fund necessary independent research in
order to enable compliance with mandatory annual methane reduction
targets of 25 percent by 2020, 50 percent by 2025 and 75 percent by
2030.


9: CA ARB should require the dairy and livestock industry to fund
further independent research that explores the viability of methane
gas bio-filtration/bioreactors at dairy and beef-product CAFOs, as
well as feed/drink-accessible cow methane respirators. CA ARB
should also require that independent research into other
significant methane-reduction strategies be funded at significant
levels by private industry. No public funding should be used for
any of this research. No further Greenhouse Gas Reduction Fund
(GGRF) resources should be allocated to subsidizing the dairy and
livestock industries in any manner, due to the intrinsically
anti-social and anti-ecological methane-emission-related
consequences of these industries. 




10: CA ARB should modify any American Carbon Registry offset
protocols currently in use and up for consideration to incorporate
either an updated 10-year interval or 20-year interval methane GWP
constant. ACR protocols retain a very low, outdated 100-year
interval methane GWP constant to preserve carbon credit fungibility
over a 100-year period. It is irresponsible for CA ARB to concur
with such narrow economic logic in the face of the disturbing
climate change-related effects increasingly appear-ing on our
rapidly-warming planet.
 
11: Mandatory carbon credit insurance should also be incorporated
into the cost of any carbon offset credit sold to enable new
scientific information to be rapidly reflected in updated and
revised SLCP GWP constants.


11: Claims made by previous commenters concerning the
methane-related emission of grass-fed versus grain-fed livestock
are questionable. Various claims and the research supporting such
claims conflict within the scientific literature. It is not clear
that enteric emissions from livestock on pasture are less than
livestock enteric emissions from livestock in CAFOs.

Moreover, claims concerning the value of pasture-based dairy
operation concerning soil carbon sequestration are especially
questionable. Typi-cally, the effective GHG impact of enteric
emissions occurring on such operations have been discounted in the
most frequently-cited studies by ignoring enteric emissions
altogether or through the use of very low and outdated methane GWPs
in the GHG-balancing methodologies of such studies.

Nonetheless, methane emissions from pasture-based operations will
be less overall relative to CAFO dairy operations due to much
smaller manure-related methane emissions and the smaller numbers of
livestock that are typically involved. In this light, I concur with
the C4RP&E June 10, 2015 comment: “Pasture-based systems stock
fewer cows per acre than confinement systems, which reduces enteric
emissions. ‘The amount of methane emitted by animals is directly
related to the number of animals, so that a more intensive farm
will have higher emissions…’” Pasture-based dairy systems that
involve low manure-related methane emissions and low numbers of
livestock relative to current CAFO dairy sys-tems are superior in
terms of SLCP reduction value. In addition, water usage devoted to
livestock and dairy production would also likely decline if
pasture-based dairy systems become ascendant economally and the
overall numbers of livestock in pasture-based systems remain
cumulatively and substantially lower than in CAFO-based dairy
systems.
 
Regardless, all livestock producers need to be treated like the
operators of coal-fired electricity genera-tion providers -- they
need to be prodded into stopping the externalization of their
private production-related environmental costs onto the broader
societies and natural ecosystems on this planet. 

Methane polluters should be taxed or fined for the methane
pollution they generate, with the tax or fine based upon a
methane-into-CO2-equivalency conversion algorithm that incorporates
a 10-year interval me-thane GWP (at best) or a 20-year interval
methane GWP (at worst).

Sincerely,

Todd Shuman, Senior Analyst, Wasteful UnReasonable Use (WURU),
Camarillo, CA 805.987.8203, tshublu@yahoo.com

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Date and Time Comment Was Submitted: 2015-10-30 10:31:14



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