Comment Log Display

I appreciate the opportunity to comment on the AB 32 Scoping Plan. 
This will serve as the Gold Standard nationally for addressing
climate change.

The Scoping Plan gets a lot right and you are to be commended for
your difficult work.  A major concern is the ability to implement
it.  Here is a "report from the trenches" from an organization that
has been working to put in place voluntary measures related to
agriculture.  We have been specifically focusing on measures that
reduce greenhouse gas emissions while improving air and water
quality.  However we have encountered  significant barriers that
are proving difficult to surmount. 

For example, we have pioneered conservation tillage, a way to
prepare land for crop production that reduces dust and diesel
emissions while sequestering carbon in soil.  When we started there
were only a couple hundred acres under conservation tillage while
today there are tens of thousands of acres. But our efforts are
being hindered as funding for a key partner, UC Cooperative
Extension, continue to be cut.  That will make it much more
difficult to significantly expand acreage further.

We also have been developing carbon negative California biofuels
that have no food for fuel trade-off. Unfortunately, State funding
as been sparse at best and we have had to operate with much less
funding than is needed to fully commercialize  beneficial biofuel
production systems.

Additionally, we have pioneered renewable biomethane both  as a
natural gas substitute and for vehicle fuel to displace dirty
diesel in trucks.  The first biomethane powered heavy duty diesel
truck is coming on line later this year.  However, a second project
is stalled for lack of funding.  We hope AB 118 funding can be
brought to bear but that is only a first step.  We are hoping the
State can play a greater role in encouraging these clean air,
greenhouse gas reducing transportation options.

We have also helped to create a new renewable energy industry,
specifically biogas digesters using agricultural waste like dairy
manure.  Biogas digesters, an early action measure identified in
the scoping plan, can improve water and air quality in addition to
reducing up to 1 million metric tons of CO2 equivalent GHG.
Unfortunately new requirements from the San Joaquin Valley Air
District will likely stop development of new digesters and may shut
down some existing facilities.  We are working on solutions to
overcome these obstacles but we have found that State officials are
poorly informed about what is happening on the ground and that is
making matters worse.

Likewise for composting facilities.  We have helped to develop new
models of co-composting that can reduce greenhouse gas emissions
while improving air quality.  But new rules threaten to close
existing facilities and prevent new ones from opening even though
they have significant air, water and GHG benefits.

Institutional barriers, particularly the "silo" approach to
regulation, threaten to undermine these efforts.  There can be 100
units of environmental benefit and 5 units of liability and that
will be considered "backsliding".  The net result is what I term,
"regulatory sudden death". That occurs when a pollutant goes over a
regulatory threshold by any amount, irrespective of the overall
project benefit.  The concept of "net environmental benefit" must
be factored into State agency approaches to AB 32 implementation. 
There are ways to do this within existing regulatory structures. 
But there must be a recognition of the problem and a willingness to
fix it.  That has not happened yet with key agency decision-makers.
 It needs to happen.