Comment Log Display

Comment Log Display

Below is the comment you selected to display.
Comment 33 for Agriculture Comments for the GHG Scoping Plan (sp-agriculture-ws) - 1st Workshop.


First Name: David
Last Name: Cranston
Email Address: dcranston@ggfirm.com
Affiliation: Greenberg Glusker LLP

Subject: Comments on behalf of CARES
Comment:
October 2, 2008

Mary D. Nichols, Chair
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Re:	Comments to Draft Scoping Plan

Dear Ms. Nichols:

On behalf of the Community Alliance for Responsible Environmental
Stewardship (“CARES”), we submit the following comments to the
California Air Resources Board’s draft Scoping Plan.  CARES is an
environmental coalition of California’s dairy producer and
processor associations, including the state’s largest producer
trade associations (Western United Dairymen, California Dairy
Campaign and Milk Producers Council) and the largest milk
processing companies and cooperatives (including California
Dairies, Inc., Dairy Farmers of America-California and Land O’
Lakes).  Formed in 2001, CARES is dedicated to promoting a balance
of economic and environmental sustainability for California
dairies.

CARES agrees that the voluntary implementation of manure digester
systems can be an important element in California’s effort to
reduce greenhouse gases pursuant to AB 32’s mandate.  We agree
with the Scoping Plan’s assessment that “economic incentives such
as marketable emission reduction credits, favorable utility
contracts, or renewable energy incentives will be needed” in order
to make manure digesters an economically viable opportunity for
California’s dairy farms.  With such economic incentives, we
believe that California’s dairy farms can become an important
source of GHG emission reductions in years to come.

For the vast majority of California’s family owned and operated
dairy farms, the costs of building and operating a manure digester
systems are prohibitive.   Manure digesters are still very much a
developing technology.  High routine and non-routine maintenance
and operational costs are the norm.  Unlike other businesses,
dairies are unable to pass along increased capital and operating
costs as the price of milk is set by the California Department of
Food and Agriculture under its Agriculture Milk Stabilization
Plan.  The thin operating margins that most dairy farmers operate
under are simply incapable of absorbing the additional costs
necessary for the installation and operation of methane digesters.
 

Some income to partially offset costs may be available through
sales of excess power to utilities.  And for those dairy farmers
that are located near utility pipelines and other necessary
infrastructure, the transmission of biogas directly from the farm
to a utility facility may be a more viable alternative.

In any event, more study is necessary to develop a sustainable
business model from which dairy farmers can develop the
infrastructure and efficiencies necessary to realize meaningful
income from the capture of methane.  Economic assistance to
conduct such studies will help spur the development and
implementation of viable models.

Even if reliable income from sale of methane or energy can be
accomplished, for the vast majority of dairy farmers, manure
digesters will remain economically unfeasible without the
availability of income from the sale of marketable emission
reduction credits.  Once the market for emission credit matures,
dairy farmers should be in a better position to attract the
investment necessary for the implementation of methane digesters
on a larger scale.  It is our hope that California dairies will
play an important role in a market-based cap and trade system by
providing a source of marketable credits for those industries who
would otherwise be unable to economically meet their greenhouse
gas (GHG) emission “caps.” 

As the Air Resources Board recognizes, the anticipated income from
marketable emission reduction credits that can make methane
digesters a reality on a large scale will not be possible if
methane digesters become mandated.  Hence, voluntary - and not
mandatory - implementation of methane digesters holds the best
potential for meaningful reductions in GHGs from California dairy
farms.

Indeed, the continued growth of the dairy industry in California
alone will help achieve GHG reductions.  Modern California dairies
are well known for their efficiency and high productivity.  More
milk from less cows means fewer GHG emissions per gallon of milk. 
The shift in the production of milk to California dairies
essentially means a shift in production that emits less GHGs.  The
California dairy industry takes great pride in its commitment to
sustainability.  With such commitment, we can expect that such
operations will only become more efficient and sustainable.

On behalf of CARES, we look forward to working with the ARB in
reaching AB 32’s goals for reducing GHGs.

Sincerely,

David E. Cranston
DEC/sl
cc:	William Van Dam, Chair, CARES
 

Attachment: www.arb.ca.gov/lists/sp-agriculture-ws/33-inte7.pdf

Original File Name: intE7.PDF

Date and Time Comment Was Submitted: 2008-10-02 16:37:46



If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.


Board Comments Home

preload