California Air Resources Board

We appreciate the opportunity to provide comments on the initial regulation for SB 253, as this regulation poses significant risks for California Dairies, Inc. (CDI), a farmer-owned milk marketing and processing cooperative representing nearly 300 family-owned California dairy farms. As detailed, risks include, but are not limited to, the disruption of supply chain investments made directly to farms coupled with the financial burden of reporting, both of which will result in a higher market price of food to consumers, as well as the inevitable result of premature accounting systems creating mass liability of inaccurate accounting for greenhouse gas emissions.

A passive omission of the guaranteed consequences of enacting this regulation would be irresponsible of the California Air Resource Control Board (CARB). Please see the comprehensive breakdown included to understand the severity of the operational, economic, and environmental distortions that will arise should this regulation move forward without substantial revision. These impacts extend far beyond administrative inconvenience; they threaten the long-term viability of family farms, undermine ongoing sustainability progress, and create systemic uncertainty across the dairy supply chain.