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Comment 50 for Scoping Plan Update Discussion Draft and Workshop Comments Log (draft-update-sp-ws) - 1st Workshop.


First Name: Seth
Last Name: Shonkoff
Email Address: sshonkoff@psehealthyenergy.org
Affiliation: PSE and UC Berkeley

Subject: PSE Comments on AB 32 Scoping Plan Draft
Comment:

AB 32 Climate Change Scoping Plan First Update: 
Comments and Recommendations

Comments Submitted to the California Environmental Protection
Agency 
Air and Resources Board (CARB)

by

Seth B. Shonkoff, PhD, MPH (1,2)

(1) Executive Director
Physicians, Scientists & Engineers for Healthy Energy, Inc. (PSE)
436 14th Street, Suite 808
Oakland, CA 94612

(2) Visiting Scholar
Department of Environmental Science Policy & Management
University of California, Berkeley

sshonkoff@psehealthyenergy.org  
510.899.9706

on behalf of

Physicians, Scientists & Engineers for Healthy Energy, Inc.
http://www.psehealthyenergy.org





Dear Members of the California Air Resources Board,

Physicians Scientists & Engineers for Healthy Energy (PSE) is a
United States-based, multidisciplinary scientific non-profit that
provides evidence-based information on novel energy production
methods, such as shale gas, shale (tight) oil, and renewable energy
technologies. PSE has offices in Oakland, CA, Ithaca, NY, and New
York, NY, and maintains formal associations with faculty members at
University of California at Berkeley, Stanford University, Cornell
University, Weill Cornell Medical College, University of
Pennsylvania, and George Washington University, among other
institutions and organizations. The aim of PSE is to bring
scientific transparency to important policy issues surrounding
energy policy issues.

The Global Warming Solutions Act (AB 32) has helped California
develop a balanced approach to addressing climate change through
its development of regulations and market mechanisms. It has been
largely successful and has fostered a clean-energy economy through
new technologies, venture capital investment, and job creation.
Meanwhile, greenhouse gas emissions have dropped sharply since 2008
towards the 2020 target (427 MMT). The success of AB 32 has been
due to a number of diverse measures outlined in the 2008 scoping
plan, such as the a low carbon fuel standard, advanced clean cars,
cap-and-trade regulation, sustainable community strategies, water
efficiency, building efficiency standards, and a movement toward a
33% renewable energy portfolio standard. All of these measures are
correctly focused on the reduction of greenhouse gas emissions and
the transition to cleaner, sustainable forms of energy.

For this reason, we are concerned that the new scoping plan does
not include a measure and evaluation of carbon and carbon
equivalents stemming from oil and gas production. If California is
serious about managing climate change and reaching its 2020 and
2050 greenhouse gas emissions goals, it must include fossil fuel
production, and not only fossil fuel refining and consumption under
the cap.  Indeed, California is the fourth largest oil producer in
the lower-48 United States and data suggests that it contributes a
potentially significant amount of greenhouse gas emissions to the
atmosphere.

The production of fossil fuel resources such as oil and gas
development is a potentially significant part of the overall
lifecycle emissions (Brandt 2011; Karion, Sweeney et al. 2013;
Peischl 2013) of fossil fuels. Much of the oil currently developed
in California is very carbon intensive to produce and process
(Brandt 2011; CARB 2012). The California Air Resources Board (CARB)
reported in 2012 that more than 30% of the oil developed in
California is as carbon intensive to develop and refine as the
Alberta tar sands in Canada (CARB 2012), one of the most
climate-disrupting fuels on earth. CARB’s reporting did not include
the development of the Monterey Shale, which may be even more
carbon intensive to develop than conventionally developed oil. 
Although steam injection and other types of thermal well
stimulation techniques are likely to be the most  greenhouse gas
intensive (Brandt 2011), factors such as the production rate, well
depth, and length of the lateral well may hold implications for the
carbon intensity of shale tight oil and gas development, including
high volume hydraulic fracturing and acidization.

Evidence suggests the process of fossil fuel development including
shale tight oil and gas development using hydraulic fracturing,
acidization, and other forms of well stimulation will exacerbate
many environmental issues, particularly climate disruption due to
fugitive methane leakage throughout the lifecycle. AB 32
appropriately considers both carbon dioxide (CO2) and CO2
equivalent emissions (CO2-eq), including methane, NOx, sulfur
hexafluoride, hydroflourocarbons, and perflourocarbons. Methane is
a potent greenhouse gas with a global warming potential that is 86
times that of CO2 on the 20 year time horizon (IPCC 2013), a time
frame that is particularly relevant given AB 32’s greenhouse gas
emission goals for 2020 and 2050.  Methane is vented and leaked
into the atmosphere during shale gas and tight oil development
production and recent field measurements in the Los Angeles Basin
of California indicate that 17% of gross natural gas production is
leaked to the atmosphere (Peischl 2013), a very high number from a
climate and air quality perspective. According to the US EPA, oil
and gas development emits more methane to the atmosphere in the
United States than any other industrial process.

In addition to greenhouse gas emissions, CARB has enumerated goals
of reducing co-pollutant emissions that may be health damaging such
as volatile organic compound (VOC), nitrogen oxides (NOx), and 8-hr
ozone attainment.  While VOCs and NOx are health damaging in their
own right, these compounds are the primary anthropogenic  driver of
atmospheric production of tropospheric (ground-level) ozone a key
risk factor for asthma, other respiratory and cardiovascular
illnesses (EPA 2013).  Moreover, tropospheric ozone is also a
shorter-lived greenhouse pollutant and contributes to climate
warming (IPCC 2013).  Studies suggest that oil and gas development
increase atmospheric concentrations of ground-level (tropospheric)
ozone due to emissions of ozone precursor emissions such VOCs and
NOx (Kemball-Cook, Bar-Ilan et al. 2010; Pétron, Frost et al.
2012; Roy, Adams et al. 2013).

Other air pollution emissions from oil and gas development, and
especially high volume hydraulic fracturing (HVHF), include diesel
particulate matter, benzene, and aliphatic hydrocarbons may
contribute to health problems among populations living near oil and
gas development sites (McKenzie, Witter et al. 2012).  Failing to
put oil and gas development under the AB 32 cap could thus
potentially place an unequal environmental burden on low-income
people of color who disproportionately live in close proximity to
oil and gas development.  Much of the air pollution emissions from
oil and gas development come from the production phase and thus it
would be detrimental to exclude this stage of the overall
development from the scope of AB 32 given its stated goals.  

AB 32 is correct to focus on energy alongside transportation,
agriculture, building infrastructure, water, waste, and land use as
useful measures for lowering emissions and combating climate
change. However, if it is serious about reaching its goal it must
include more focus on oil and gas production. The comments that
follow will be directed towards climate change mitigation efforts
and progress toward the 2020 goal, focusing in particular on the
energy sector, GHG emissions, and the latest understanding of
climate science.  

1.	Change the Global Warming Potential (GWP) of Methane (CH4) to
Reflect Latest Measures from IPCC’s Fifth Assessment Report (2013)

As noted in section III(C)(b) Emission Reductions to Meet the 2020
Target of the scoping plan, most national and international climate
change organizations have move to the International Panel on
Climate Change’s (IPCC) Fourth Assessment Report (AR4) (2007) when
considering the potency (GWP) of high global warming potential
gases such as methane. Previously, the board approved a total
statewide GHG 1990 emissions level and 2020 emissions limit based
on the IPCC’s second report published in 1996. Presumably, the
decision to update the 2020 goal, weighting the 1990 emissions with
GWPs from the Fourth Assessment Report, was to incorporate the most
accurate and current scientific information on GWPs.

Given the recent publication of IPCC’s Fifth Assessment Report
(AR5) on September 26, 2013, CARB likely did not have the ability
to account for recent assessments in its scoping plan. However, the
report is available with new numbers for the GWP of methane and
other high potency greenhouse gases. CARB should incorporate these
more up-to-date numbers into its weighting scheme. 

The new IPCC Climate Change 2013 report assigns higher measures to
the global warming potential of methane of 86 over a 20-year time
frame and 34 over a 100-year time frame. This is up from 72 and 25,
respectively in AR4, meaning the GWP increased 19.4% for the
20-year time frame and 36% for the 100-year time frame. These
changes are not insignificant, however, the decision to adhere to
up-to-date consensus climate science will determine the meaning and
accuracy of CARB’s statewide GHG emission inventory, forecasts, and
targets. 

2.	Include More Discussion of Methane Emissions from Oil and Gas
Industry Under the Cap

The scoping plan draft acknowledges that methane is emitted from
the oil and gas industry during transmission when it is vented and
leaked from processing equipment and pipelines (p. 16). Then, in
the impact section concerning high global warming potential gases,
it is recommended that releases of high-GWP gases (e.g., methane)
should be avoided using gas recovery options, “such as…leak
tightness specifications” (p. 44). The Scoping Plan acknowledges a
proposal to develop a measure to reduce venting and fugitive
emissions associated with oil and gas production. The proposal will
be based upon a “survey of the industry to improve the emissions
inventory for this sector” (p. 36). 

3.	Include All Upstream (Oil and Gas Production) And Midstream (Oil
and Gas Transmission) Emission Sources Of Oil And Gas Development
Under The Cap

There are multiple greenhouse pollutant emission sources in both
the upstream (oil and gas production) and midstream (oil and gas
transmission) that should be included under the AB 32 cap.  Vented
and fugitive emissions of CH4¬, NOx, VOCs, and other greenhouse
pollutants and greenhouse pollutant precursors are known to be
emitted from multiple sources including, but not limited to:
wellhead compressors, pneumatic devices, heaters, flares, drill
rigs, natural gas dehydrators, completion venting, blowdowns,
wastewater storage tanks and sumps, and glycol dehydrators
(Kemball-Cook, Bar-Ilan et al. 2010; US EPA 2012).


Sources Cited

Brandt, A. (2011). "Oil Depletion and the Energy Efficiency of Oil
Production: The Case of California." Sustainability 3: 1833-1854.
CARB (2012). Detailed California-Modified GREET Pathway for
California Reformulated Gasoline Blendstock for Oxygenate Blending
(CARBOB) from Average Crude Refined in California. Sacramento, CA,
California Air Resources Board.
EPA, U. (2013). Integrated Science Assessment for Ozone and Related
Photochemical Oxidants. Washington, DC, United States Environmental
Protection Agency.
IPCC (2013). Working Group I Contribution To The IPCC Fifth
Assessment Report Climate Change 2013: The Physical Science Basis,
Intergovernmental Panel on Climate Change.
Karion, A., C. Sweeney, et al. (2013). "Methane emissions estimate
from airborne measurements over a western United States natural gas
field." Geophysical Research Letters: n/a-n/a.
Kemball-Cook, S., A. Bar-Ilan, et al. (2010). "Ozone impacts of
natural gas development in the Haynesville Shale." Environ Sci
Technol 44(24): 9357-9363.
McKenzie, L. M., R. Z. Witter, et al. (2012). "Human health risk
assessment of air emissions from development of unconventional
natural gas resources." Sci Total Environ 424: 79-87.
Peischl, J., et al. (2013). "Quantifying sources of methane using
light alkanes in the Los Angeles basin, California." Journal of
Geophysical Research: Atmospheres 118: 1-17.
Pétron, G., G. Frost, et al. (2012). "Hydrocarbon emissions
characterization in the Colorado Front Range: A pilot study."
Journal of Geophysical Research-Atmospheres 117(D04304): 1-19.
Roy, A., P. Adams, et al. (2013). "Air pollutant emissions from the
development, production and processing of Marcellus Shale natural
gas." Journal of the Air & Waste Management Association.
US EPA (2012). Oil and Natural Gas Sector: New Source Performance
Standards and National Emission Standards for Hazardous Air
Pollutants Reviews: 40 CFR Parts 60 and 63. Washington, DC, United
States Environmental Protection Agency.


Attachment: www.arb.ca.gov/lists/com-attach/55-draft-update-sp-ws-AHAFcARgUV0DZAhq.pdf

Original File Name: PSE AB 32 Scoping Comments_2013.11.1.pdf

Date and Time Comment Was Submitted: 2013-11-01 13:54:46



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