Post by Katharine D.

I submitted independent scientific comments to the California Air Resources Board's information solicitation on SB 1383's dairy and livestock provisions last month, focused on enteric methane methodology, inventory architecture, and the regulatory gaps around feed additive verification. The comment period ended last night, and featured submissions from Ermias Kebreab, DSc of UC Davis's Department of Animal Science, Clean Air Task Force, Climate Action California, and Aaron Smith of the Energy Institute at Haas. The approved comments can be found at https://lnkd.in/dgzVeMXD and my comment can be found at https://lnkd.in/gmH_39CC. A few things I tried to contribute that I don't think appear elsewhere in the record: - The case for decoupling California's livestock methane inventory from EPA's Cattle Enteric Fermentation Model and completing the transition to CADEM being made more urgent by the February 2026 Endangerment Finding rescission, which creates a genuine methodological independence problem for California that the rulemaking hasn't fully reckoned with. - A facility-level reporting schema designed around CADEM's actual input requirements rather than the static emission factors of the current Tier 2 approach. - A verification mechanism for feed additive compliance claims based on RFID-linked individual dosing records, the only approach that creates an auditable animal-level chain linking a specific animal to a specific dose to a specific intake event. Additionally, the corollary: why this mechanism categorically cannot work for grazing systems, which has significant implications for any compliance framework built around feed additives. - A techno-economic portfolio analysis of enteric mitigation strategies, including a detailed treatment of the unresolved bromoform safety questions that I think the field has been too optimistic about, framed as a bridging strategy rather than a list of competing options. - The argument that California's biotech infrastructure, such as the Bay Area and San Diego life sciences clusters, the UC system, represents an underutilized comparative advantage for actually solving the underlying biological problem through genomic selection and microbiome engineering, rather than managing it indefinitely with subsidized additives and contested carbon accounting. I also contributed to Climate Action California's submission, which I think is the most operationally specific set of manure management recommendations in the record. I'm now thinking about where this work goes next, both in terms of the rulemaking process and in terms of finding an organizational home where this kind of technical-regulatory bridge work can continue. If any of this is relevant to what you're working on, I'd be glad to talk. #Methane #SB1383 #AgMethane #ClimatePolicy #AgPolicy #Agriculture #GHGPolicy #OpenToWork