Problem Solvers Caucus take action on Low Carbon Fuel Standard - Petition for Direct Regulation

April 30, 2024

Chair Liane Randolph

California Air Resources Board

1001 I Street

Sacramento, CA 95814

RE: Petition for Direct Regulation

Dear Chair Randolph:

Climate scientists agree that reducing methane emissions is the most important short-term effort to limit global warming. With the passage of SB 1383 (Lara) in 2016, California has taken appropriate steps to significantly reduce methane and other short-lived climate pollutants (SLCPs) in California, as part of the state’s comprehensive climate policies. Climate-smart agricultural practices, including dairy methane reduction, are part of the solution. We urge you to continue the incentive-based approach currently being successfully employed by the California Air Resources Board.

Since SB 1383’s passage, the dairy farm families throughout California have been partnering with California’s Department of Food and Agriculture (CDFA) and the California Air Resources Board (CARB) to install more than 300 methane reduction projects on their farms. These efforts, including the Alternative Manure Management Program (AMMP) and the Dairy Digester Research and Development Program (DDRDP), remain among the state’s most cost effective and productive climate investments. The DDRDP program provides 22% of the state’s overall GHG reductions, while receiving just 1.7% of the proceeds from the Greenhouse Gas Reduction Fund (GGRF). To date, more than $2 billion has been invested, leveraging more than $700 million from the state.

According to a December 2022 UC Davis report:

“Our analysis shows that continued implementation and commitment to the incentive-based climate smart solutions that are currently driving voluntary dairy methane reductions in California should, by 2030, achieve the full 40 percent reduction in dairy methane sought by the state regulators without the need for direct regulation.”

The California Legislature remains committed to an incentive-based approach, and it is critical that CARB remain committed as well. While there are no perfect climate solutions, the state’s dairy methane reduction programs are highly effective and are resulting in the important methane reductions needed to achieve the state’s goals.

CDFA has also recently developed new Dairy-Plus programs to incent development of projects that not only provide substantial methane reductions, but significantly improve water quality outcomes in rural disadvantaged communities. The water quality benefits are an important addition to the well-documented methane, air quality, and nuisance (odor) benefits associated with these projects. CDFA has distributed $10 million for important enteric methane reduction research. Finally, the 2023-2024 budget includes funding for CDFA to establish a new program focused on incentivizing enteric methane reductions on dairy and other livestock operations.

In addition to these important incentive programs, the Low Carbon Fuel Standard (LCFS) Program has been a key driver of dairy, landfill, and wastewater methane reduction projects. CARB must continue to provide for the beneficial use of methane captured from these operations. Efforts to exclude dairy and livestock methane from the LCFS program, eliminate avoided methane crediting, or directly regulate the sectors are contrary to the intent and requirements of SB 1383.

Moreover, calls for direct regulation of dairy and livestock methane reduction will only lead to California falling well-short of our climate goals. Adopting policies that will lead to leakage is inconsistent with SB 1383 and undermines CARB’s national and world leading reputation and efforts to address climate emissions.

In conclusion, we strongly encourage CARB to deny the petition, stay the course and continue to provide the incentives needed to ensure dairy and other methane reductions are achieved consistent with the recently adopted 2022 Scoping Plan Update. At the same time, we will continue to work to ensure that rural communities have clean drinking water and clean air. As representatives of these communities, we understand first-hand the need for balanced actions to ensure our rural communities thrive.

Sincerely,

ANNA M. CABALLERO

Senator, 14th District

BILL DODD

Senator, 3rd District

JOSH NEWMAN

Senator, 29th District

MELISSA HURTADO

Senator, 16th District

ROSILICIE OCHOA BOGH

Senator, 23rd District

ROGER NIELLO

Senator, 6th District

BOB ARCHULETA

Senator, 30th District

MARIE ALVARADO-GIL

Senator, 4th District

STEVEN BRADFORD

Senator, 35th District

TOM UMBERG

Senator, 34th District

JUAN ALANIS

Assemblymember, 22nd District

ESMERALDA SORIA

Assemblymember, 27th District

JUAN CARRILLO

Assemblymember, 39th District

DEVON J. MATHIS

Assemblymember, 33rd District

BLANCA E. RUBIO

Assemblymember, 48th District

BLANCA PACHECO

Assemblymember, 64th District

DR. JASMEET KAUR BAINS

Assemblymember, 35th District

DIANE DIXON

Assemblymember, 72nd District

AVELINO VALENCIA

Assemblymember, 68th District

JOSH HOOVER

Assemblymember, 7th District

CARLOS VILLAPUDUA

Assemblymember, 13th District

JACQUI IRWIN

Assemblymember, 42nd District

MARIE WALDRON

Assemblymember, 75th District

THOMAS LACKEY

Assemblymember, 34th District

LAURIE DAVIES

Assemblymember, 74th District

HEATH FLORA

Assemblymember, 9th District

CC:

Governor Gavin Newsom

Secretary Karen Ross, California Department of Food and Agriculture

Dr. Steve Cliff, CARB Executive Officer

John Eisenhut

Dr. Susan Shaheen

Dr. John Balmes

Diane Takvorian

Cliff Rechtshaffen

Dean Florez

Hector De La Torre

Davina Hurt

V. Manuel Perez

Eric Guerra

Nora Vargas

Dr. Tania Pacheco-Werner

Gideon Kracov

Senator Henry Stern

Assemblymember Eduardo Garcia

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