Comment Log Display

Methane is the priority for immediate large reductions
Comments on the Draft SLCP Plan by Jim Stewart, PhD
1.	The Draft SLCP Plan is helpful in that it provides totals of
emissions based on the updated AR5 20-year GWPs, but it should
state the need to apply these to update the overall Scoping Plan,
cap-and-trade income, and especially the allocation of revenues to
be comparable to the global warming impacts.
2.	It would be much better to use instantaneous radiative forcing
values than GWPs, because the planet is in an immediate global
warming crisis that cannot wait twenty years for reductions.
3.	The Draft SLCP Plan shows a target of a reduction in methane
levels from 118 in 2013 to 71 MMTCO2e by 2030, but needs to show a
clear plan to get there.  In addition, the methane target should be
consistent with the Governor’s goal of 40% reductions by 2030,
which would be 47 MMTCO2e.  This is especially important since many
methane reduction strategies are far cheaper per ton than carbon
reductions. 
4.	Dairy manure reductions are stated as “voluntary”, but need to
be mandatory. Strategies should include eliminating connection fees
for electricity produced from dairy manure digesters.
5.	Enteric emissions need to be addressed beyond “more research.” 
One way to do this would be to include them in cap-and-trade.
6.	Current emissions from landfills can be reduced by using small
active cells with immediate impermeable capping in the critical
first few days after organics are dumped and most of the methane is
produced.  
7.	Future emissions from landfills can be addressed by quickly
diverting all organics from landfills, East Bay Municipal Utility
District is proposing to do it in less than five years (while ARB
is proposing ten).
8.	Emissions from past landfills need to be reduced by better
capping and by cleaning the gas and feeding the gas into sources
that can use it directly (such as pipelines and fuel cells). 
9.	Ban the use of small internal combustion engines to burn
methane, since the pass-through of unburned methane eliminates the
climate benefit (but turbines are okay). 
10.	The high rates of observed fugitive methane emissions from gas
and oil wells and associated facilities, especially those in Kern
County and Los Angeles County need to be targeted immediately and
eliminated in less than a year.  JPL drones have begun the process
and proven the technology works well, especially when coordinated
with ground observations to pinpoint the sources.  They should be
paid for by large fines on fugitive emissions.
11.	Black carbon emissions from on-road vehicles need to be reduced
faster and off-road vehicles need to be on a similar track. Much
more resources need to be put into black carbon since the ARB First
Update to the Climate Change Scoping Plan says on page 17 that
black carbon is 15% of the 2010 inventory (using AR5 20 year GWP).