Comment Log Display

The Air Resources Board estimates that agriculture in California
releases 6% of our global warming emissions. Research indicates
that modifying our existing agricultural systems can transform
agricultural lands from emissions sources to emissions sinks. Yet
the Air Resources Board proposed scoping plan includes just 1 page
of proposals relevant to agriculture, suggesting voluntary methane
digestion facilities at large dairies, and describing an on-going
research project on agricultural emissions of the global warming
gas nitrous oxide.

The proposed scoping plan ignores many opportunities to use
agricultural means to reduce global warming emissions, including
measures that would directly benefit underprivileged communities in
the inner city and farm workers. We ask that the Board evaluate
fully the universe of global warming emissions reductions possible
in the agricultural sector, with special attention to those
measures that benefit disadvantaged communities. We recommend
amending the proposed scoping plan to include measures and research
in the following 3 areas:

Urban agriculture
The Air Resources Board is actively encouraging urban forestry
through approval of a methodology for quantifying voluntary
reductions accrued by planting trees. The Board should outline a
similar methodology associated with the creation of community
gardens in urban areas. Community gardens can sequester carbon in
the soil, and reduce the use of fuel to transport fresh produce to
urban areas. Modeling a program after Oakland’s Food Policy and
Plan (Oakland City Council Resolution No. 79680) to require urban
areas to source a percentage of their food locally would also
dramatically decrease the number of food miles needed to transport
food, thus decreasing fuel use and greenhouse gas emissions.
Decreasing the size of inner city areas known as “food deserts,”
areas, in which the only food available is expensive, highly
processed and packaged, or low quality would benefit minority,
immigrant, and low-income communities. Environmental justice
co-benefits include improved nutrition and health of the
communities served, and creation of welcoming public spaces for
local residents to enjoy.

Organic agriculture
Decreased use of pesticides and synthetic fertilizers can reduce
the significant energy inputs required to produce these chemicals,
while simultaneously reducing harmful chemical exposures to farm
workers. Agricultural research also indicates organic farms
sequester more carbon within the soil, and may release similar
amounts of nitrous oxide. We recommend immediate implementation of
a targeted research program to quantify the overall global warming
footprint of organic versus conventional farm practices.

Agriculture within the cap and trade framework
Agricultural offsets may be a useful means of reducing global
warming emissions in California. If offsets become a major means by
which capped sectors reduce emissions, however, the cap and trade
system will fail to foster the technological innovations necessary
to move California away from fossil fuels, and will allow continued
exposures of fenceline communities near refineries and power plants
to toxic air contaminants. 

Review of the proposed scoping plan and related documents
indicates that the Air Resources Board has not provided a
comprehensive investigation of these and other opportunities to
reduce global warming emissions through agriculture. As part of “an
open public process,” the Board should publish feasibility and cost
evaluations of the measures described above.

We are pleased to have the opportunity to provide public comments
for the Board’s consideration. We ask that the Board amend the
scoping plan to take full advantage of the additional opportunities
to achieve greenhouse gas emission reductions through improvements
in the environmental performance of agriculture. We also ask the
Board to provide a clear and detailed account of the reasoning it
uses to identify and evaluate measures to reduce global warming
emissions in agriculture and all other sectors in California.