Comment Log Display

re: B001901    Open Sky Ranch, Riverdale

There are two major problems with this proposal or application and
analysis.
 
First, this proposed project by Open Sky Ranch Dairy has no net
benefits for the local low-income community nearby in Riverdale and
in the surrounding area of Fresno County. The San Joaquin Valley,
including Fresno County, is not in compliance with several of the
federal health standards set under the authority of the Clean Air
Act. Ozone and PM2.5 are two categories of air pollution where
compliance is severely lacking. We should not have to detail in
these comments the health effects of local air pollution but
premature death is the most obvious consequence.

This proposal will produce methane in a manure digester and burn it
nearby for the purpose of generating electricity even though there
is plenty of electricity already in the local grid to supply the
needs of the dairy which is produced more cleanly. The result of
this digester and electrical generation through combustion will
impact local air quality through the creation of NOx. NOx is key to
ozone formation in the warm months of the SJV and is key to a
majority of PM2.5 formation in the cooler months. The need to
reduce NOx emissions in the San Joaquin Valley is the key to the
valley reaching compliance with the federal clean air standards.

This project, because it will make local air quality worse, is in
conflict with the language of AB32 which, in summary, says that
efforts to reduce GHG emissions should not compromise or conflict
with efforts to reduce air pollution in nonattainment areas.

Second, the Low Carbon Fuel Standard requires that each fuel
pathway receive a life-cycle assessment of all related GHG
emissions, both direct and indirect. It seems that this has not
been done for the analysis of carbon intensity of the electricity
to be produced by this project. It may be that the guidance from
CARB for this type of project is incorrect as well.

The manure must be produced in order for this project to both
produce and collect methane for the purpose of combustion in an
electrical generator. No analysis has been done regarding the GHG
emissions involved in the production of this manure. The GHG
emissions of the dairy regarding the milk produced are not
regulated. Therefore, these emissions must be applied to the manure
and to the methane created from that manure. This methane is
created on purpose, not by chance, through the liquefication of the
manure. The business of producing and collecting this methane is
for the intent of making a profit. This should be obvious.
 
In conclusion, this project should be denied because it will harm
local air quality. If the harm to local air quality is mitigated,
then before approval, a complete life-cycle assessment of how the
methane is created, including everything associated with the cows
creating the manure, must be completed.

Tom Frantz
President, Association of Irritated Residents