Title: Comments on Regional Greenhouse Gas Initiative (Rggi) Draft Model Rule Authors
Submitted to: Electronic Publication
Publication Type: Other
Publication Acceptance Date: May 22, 2006
Publication Date: May 22, 2006
Citation: Vanotti, M.B., Szogi, A.A. 2006. Comments on Regional Greenhouse Gas Initiative (RGGI) draft model rule. Available: http://www.rggi.org/stakeholder_comments_model_rule.htm Technical Abstract: Our comment for the Regional Greenhouse Gas Initiative (RGGI) Staff Working Group is to consider expanding the type of technologies that can qualify for the award of CO2 emissions offset allowances, under Section XX-10.5 CO2 Emissions Offset Project standards, Subdivision (e) Avoided methane emissions from agricultural manure management operations of the Public Review Model Rule Draft 03.23/06 (http://www.rggi.org/). As currently written, only anaerobic digesters can be accepted for generation of credits. Our recommendation is to also include projects that reduce greenhouse gas (GHG) emissions using aerobic treatment systems. In these comments we provide a brief description of the alternative approaches and demonstration of GHG emissions reductions that result when aerobic systems are implemented in confined swine operations. The offset portion of the draft model rule can be substantially improved with the incorporation of advanced technologies that use aerobic treatment such as the recently approved environmentally superior technologies (EST) developed to replace anaerobic swine lagoons in North Carolina. In addition to the strict environmental standards that EST's need to comply with (i.e. the elimination of pathogens, ammonia emissions, odor, heavy metals, phosphorus, discharge to surface and ground water, etc.), they are also very effective reducing GHG emissions (both methane and N2O), even more than anaerobic digesters per-se. Therefore, if the objective of a CO2 emissions offset project is to help reduce GHG emissions from animal manure management operations, then there is no scientific basis to exclude the aerobic treatment approach from the model rule under consideration, especially when these technologies have been developed and are readily available for use.