Proposed Short-Lived Climate Pollutant Reduction Strategy

uncertainties, 39 measurement methods are often difficult and less precise, 40 and carbon
costs are hard to assign with the same reliability as for combustion sources of CO 2 . 41
Because of these difficulties, and the importance of seeking SLCP-specific emission
reductions, which the Cap-and-Trade Program is not designed to produce, this
Proposed Strategy does not recommend expanding Cap-and-Trade Program
coverage. 42 Instead, the Proposed Strategy focuses on specific measures for
SLCP-emitting sectors, consistent with the approach ARB adopted while developing the
AB 32 Scoping Plan and Cap-and-Trade Program.
ARB notes that stakeholders have expressed divergent views on this basic approach as
it relates to animal agriculture. On one hand, the Animal Legal Defense Fund has
petitioned ARB to include emissions from that sector in the Cap-and-Trade Program.
On the other hand, representatives of many environmental justice and environmental
groups have argued that direct, sector-specific measures are preferable, as have
representatives of the dairy industry. This Proposed Strategy focuses on direct
measures, consistent with the necessity of reducing SLCP emissions from the dairy
sector specifically, and in-line with the design principles that underlie the State's climate
strategy and the Cap-and-Trade Regulation. 43
39 Western Climate Initiative, Inc. (2010) WCI Comments on the Proposed Mandatory Reporting of GHG
Emissions from Proposed Reporting for Oil and Gas Operations (Subpart W) at pg. 39. available at
http://www.westernclimateinitiative.org/document-archives/funcdownload/258/chk,ab6041717dc1be9cd3430f4f7585cb8e/no_html,1/.
40 California Air Resources Board (2011) California’s Cap-and-Trade Program Final Statement of
Reasons, Response to Comment E-69, pg. 430 and 448. available at
http://www.arb.ca.gov/regact/2010/capandtrade10/fsor.pdf.
41 Id., Response to Comment E-31, at pg. 425. available at
http://www.arb.ca.gov/regact/2010/capandtrade10/fsor.pdf.
42 ARB considered this option in detail, however. Further discussion is available in the California
Environmental Quality Act (CEQA) appendix to this Proposed Strategy (Appendix C).
43 The Livestock Project Compliance Offset Protocol is one such more focused measure now in operation.
It contrasts with the wholesale coverage of the sector by the Cap-and-Trade Program that some
stakeholders suggest. This protocol, focused on encouraging sector-specific reductions, would not
operate if facilities in the sector had compliance obligations in the Program. The protocol balances the
need for clear quantification methodologies and regulatory program requirements and ensures any
credited voluntary GHG emission reductions meet the AB 32 criteria. The quantification methods included
in this protocol use conservative factors to ensure that only real emission reductions are eligible for
issuance of compliance offset credit.
30 April 11, 2016