Comment Log Display

Gentleman:

I am deeply concerned about the proposed timing of agricultural
early action # 8, "manure management" (methane digester protocol)
and agricultural early action # 31, “collaborative research on
greenhouse gas reductions from land application”.  The anaerobic
digestion of manure should not be implemented without the control
of ammonia and nitrogen emissions.  The manure management protocol
is scheduled to be completed by the third quarter of 2008 whereas
the collaborative research on greenhouse gas emissions will not be
completed until the fourth quarter of 2010.

As you must be aware the Central Valley of California suffers from
significant ammonia emissions from the existing manure holding
ponds.  Although the existing manure holding ponds are very
inefficient anaerobic reactors (partially covered anaerobic and
anaerobic ponds) they still emit ammonia loads that are toxic. 
Implementation of more efficient anaerobic reactors will result in
even larger discharges of ammonia.  The ammonia will be discharged
with the liquid effluent from the anaerobic reactor.  Covering
lagoons will not control the ammonia discharges.  Ammonia
discharges will only be enhanced by covering the ponds since
ammonia will be emitted from the irrigation water.

The ammonia discharges are in and of themselves toxic.  They lead
to the formation of PM 2.5 that is also hazardous to human health.
 Ammonia discharges will eventually be deposited on agricultural
lands and undergo nitrification and denitrification leading to
significant nitrous oxide emissions.

The bottom line is that in an effort to control methane emissions
from open ponds, by covering those ponds and thereby creating more
efficient anaerobic reactors, that we will increase the discharge
of toxic gaseous pollutants as well as other powerful greenhouse
gases.  If you implement a methane control strategy from
agricultural ponds you must also implement an ammonia nitrogen
control strategy for the liquid and gaseous effluents from most
ponds.  Options to be considered include the use of aerobic
treatment technologies, ammonia stripping and sequestering
technologies, and or delays in implementing early action number 8
until early action number 31 has been completed.


Sincerely,



Dennis A. Burke PE (C 21404)