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Plain text version of comments follows; also included as an
attachment in Microsoft Word. The text version below omits the
footnote references in the Word document. 
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AB32 Proposed Scoping Plan and (Non) Regulation of Agricultural
Emissions

December 10, 2008

Submitted by:

Adam Lazar (SBN 237485) 
1726 Page St Apt. 3
San Francisco, CA 94117

On behalf of myself and the public interest, I respectfully submit
these comments regarding agricultural emissions of greenhouse gases
in the AB32 Proposed Scoping Plan.  

The AB32 Proposed Scoping Plan identifies agriculture and food
processing as the source of 9% of California’s greenhouse gas
emissions.   Given the limited estimation of agricultural emissions
by the ARB, and the omission of fertilizer-related emissions, this
number is likely far less than the actual total agricultural
emissions. 

With such a significant amount of GHG emissions at stake, no
exception for agricultural sources should be made under AB32.  Yet
the Scoping Plan provides a near-total exclusion of agriculture
from emissions reductions.  Instead of providing meaningful
regulation of this source, the scoping plan goes only so far as to
provide for voluntary reductions through usage of manure digesters
at CAFO dairy operations.   The Proposed Scoping Plan foresees no
mandatory regulation of agricultural sources in the short term, and
the possibility of only a very limited degree of regulation in the
long-term.  Lest one think the ARB belives this to be meaningful
emissions reduction, the measure is given no reduction credit short
term and only 1 long-term.  Even the extremely early-stage and
speculative California High Speed Rail receives more credit. 

The Scoping Plan should include meaningful measures to reduce the
methane gas from Concentrated Animal Feeding Operations.   On the
one hand, these measures could compel the manure digesters already
described in the Plan, and should additionally include mandatory
capture from enclosed cattle buildings at CAFO’s and covered
storage for animal waste lagoons.  Not only would such mandatory
covering work in tandem with requiring waste digesters, resulting
in an immediate reduction in methane gases, but it would have
tremendous co-benefits for public health from the reduction in
airborne particulate matter.  Likewise, prohibiting the open
exposure (e.g. drying) of animal waste would further reduce methane
and particle emissions.   

All of these controls could be required in a meaningful regime of
agricultural emissions reductions.  However, given the market-based
leanings of the AB32 Scoping Plan, the best solution may be to
include agricultural emissions in the cap-and-trade system. 

Methane capture is an accepted practice with over thirty
participating dairies in the Central Valley alone.    A recent
study of Central Valley dairies concluded that many digester
systems are already on the market.   Notably, the study concludes
that GHG emissions from CAFO’s should be included in a
cap-and-trade system.  When integrated into cap-and-trade, the
study finds that the GHG offsets combined with electricity
generation create a positive cash balance for a farmer.   Given
this potential, the ARB should not hesitate to bring agriculture
under the system. 


Co-Benefits of Improved Waste Holding Requirements for Methane and
Particulates
Methane capture at CAFO’s is perhaps unique in the tremendous
co-benefits afforded by its process; these co-benefits include both
energy production and a major decrease in regional airborne
particulate matter. 

 A critical missed co-benefit in the AB32 Scoping Plan is the
improvement in air quality from isolating animal waste lagoons from
direct exposure.   This isolation is a complimentary result to
instituting a waste digestion system in a CAFO’s as considered as a
voluntary measure.  

Need to Include Fertilizer-Related Emissions In Agricultural GHG
The Plan credits these emissions to “largely methane emissions
from animals and their waste.”   However, agricultural fertilizer
application should also be included in this sum, which would be no
small addition—as much as 90 million metric tons of CO2 per year
are used by CAFO’s, a full half of which is attributable to food
crop production.    Further, at least one study notes that
fertilizer must be included in the emissions regulatory regime
because otherwise the methane capture practices “could induce
secondary effects that diminish water quality (e.g. switching to
crops with greater fertilizer requirements.)”   Even so, the study
concludes that between 60 and 70 million tons of crop-related
carbon emissions can be mitigated—while leading to a 2% improvement
in water quality. 

Even with the inclusion of fertilizer, however, the Scoping Plan
underestimates the contribution of CAFO’s to localized and highly
concentrated greenhouse gas emissions in California.  The plan does
not acknowledge that California’s Central Valley contains the
highest concentration of dairy CAFO’s in the world, leading to an
inordinately high level of localized greenhouse gas emissions. 
Combine this concentration with a recent study delineating the
contribution to greenhouse gas emissions from agricultural sources
that “surpass those of the transportation sector,”  and it is
reasonable to conclude that agricultural emissions contribute far
more than 9% of state greenhouse gas emissions. 


Conclusion
Do not give agriculture an exception to AB32.  The California
Legislature made no such exception in their legislation, and the
ARB’s exclusion of this sector from the Scoping Plan is a violation
of the letter and intent of the law.  Global farm animal production
is expected to double by 2050.  We must act now to combat this
challenge.