Comment Log Display

Regarding:
SUMMARY # C14
ID NUMBER: EJAC-3/ARB 2-12
TITLE : REDUCE METHANE VENTING/LEAKS FROM OIL AND GAS
SYSTEMS
PROPONENT: ENVIRONMENTAL JUSTICE ADVISORY COMMITTEE AND
CALIFORNIA AIR POLLUTION CONTROL OFFICERS ASSOCIATION

In the description, you are missing emissions from Natural Gas
Storage Facilities in California. From work I've done in the past
for the PUC, I know there can be -- and are -- significant losses
of natural gas to the surface from underground storage facilities.
The losses can be managed and held to a minimum by the way they
operate the facilities. Proper management would reduce the amount
of gas they can store. Although storage may be necessary to the
industry to manage level gas supplies in the public system, the
quantity stored could be less to accomplish the same goal. (The
competing purpose of storing gas is to allow utilities to take
advantage of wholesale gas price swings.) You would have to weigh
the pricing advantage to the consumers against the value of
reduced air emissions.