California Air Resources Board

Dear CARB Staff,

We appreciate the opportunity to submit comments on the Implementation of the Dairy and Livestock Provision of SB 1383 (Lara, 2016) which established the state’s rapidly-approaching 2030 methane reduction target. Dairy operations play a major part of our state’s economy, but they also have a substantial impact on our environment and health due to the high levels of methane they produce. As a short-lived climate pollutant with outsized warming capacity, mitigating methane emissions is key to California’s GHG reduction goals. The global warming potential of methane is 80 times greater than carbon dioxide in the short run - mitigating methane today yields substantial climate benefits for the future of emissions. Currently, California’s existing methane management strategy only addresses the waste and oil and gas industries, leaving an unwarranted exception for agricultural emissions.
Methane emissions from dairy livestock produce severe consequences for the environment, and many Californians living near these operations share deep concerns about the lack of a comprehensive regulation in this sector. Much of California’s dairy industry is concentrated in regions like the Central Valley, which is already struggling with poor air quality and water contamination. Methane management is not only critical for reducing the impacts of climate change, but also essential for protecting the health of our communities who are most impacted and suffer disproportionately from pollution from industrial-scale dairy farms.

SB 1383 sets clear goals that require California reduce methane emissions specifically from dairies and livestock to 40% below 2013 levels by 2030. This mandate provides a crucial opportunity for CARB to pursue methane reductions in ways that are both climate effective and community focused. As CARB moves forward with regulatory development, it is essential that the agency adopts strong and enforceable regulations that will result in real, measurable, and long-term emissions reductions. To contrast this unregulated sector to the standards of CARB’s existing Landfill Methane Regulation, it is paramount that the dairy sector is subject to similar enforceable monitoring, reporting, and mitigation timelines. For reported emission reductions to be legitimate, reductions under LCFS cannot additionally contribute to the SB 1383 target. Additionally, the utilization of modern remote sensing tools like satellites that can detect methane hotspots regardless of sector can provide a unique opportunity to get data rapidly. As this data becomes available, facility owners and operators must be subject to reasonable timelines for mitigating methane emissions when levels reach unacceptable thresholds.

Regulations must prioritize direct emissions reductions while advancing environmental justice outcomes for communities in regions like the Central Valley, where the majority of large dairy operations are concentrated. Residents of the region are already facing severe pollution and environmental health burdens due to other agricultural and transportation emissions that experience a compounding effect with dairy and livestock emissions. Beyond the global warming impact of methane, dairy operations have a known detrimental impact on air and water pollution.

To maximize incentives, operators conduct manure production practices with poor environmental outcomes, which continuously expands more extreme odor days to adjacent communities. It is furthermore unsustainable to rely solely on incentives to mitigate emissions when rather than continuing to subsidize industrial dairy operations under the premise of advanced “clean” biofuels and methane reduction strategies, CARB must undertake regulation and enforcement typical of other methane-emitting sectors. CARB needs to prioritize actionable, timely solutions that will reduce methane emissions to meet the 2030 target, while protecting frontline communities and delivering legitimate environmental health benefits.

We look forward to engaging with CARB in the development of strong standards to reduce methane from the dairy and livestock sector.

Regards,

Pa Houa Lee
Central Valley Regional Organizer
California Environmental Voters