Comment Log Display

The legislation proposed under the auspices of AB 32 The California
Global Warming Solutions Act of 2006, is ground-breaking,
progressive and an important step in the right direction towards a
national dialog and emissions reduction program in concert with a
credible national energy policy.  The legislation has been followed
up by the recently-released “Climate Change Proposed Scoping Plan,
October 2008” which lays out the implementation of AB 32, which is
also an important step towards defining the requirements, needs,
and methodology to meet the reductions mandated under AB32. 
However, “Tracking and Measuring Progress” (Section IV-D) is
fundamentally flawed in its assumptions and implementation in
nearly exclusively relying upon a ‘bottom-up’ inventorying methods
for quantifying and tracking “greenhouse gas” (GHG) emissions. 
There is a large and extensive scientific literature base which
documents that such inventories can be off by factors of two (2) or
more.  This is the case nationally in the US where the bottom up
estimate of SF6 emissions are close to a factor of three (3) lower
than what is required to match what is observed in the atmosphere. 
This single example shares commonality with other estimates of
other emissions which show that bottom-up inventories are always
biased to UNDERESTIMATING the true emissions.  This is the case
even when there are not substantial financial incentives and
dis-incentives to ‘gerrymander’ the inventory to meet a specific
outcome (eg., when cap and trade, “mitigation” efforts, and
“carbon” auctions, each of which carries financial benefits and
incentives for specific players, are being combined in the case of
AB 32’s implementation). 

A credible, scientifically defensible estimate of GHG emissions
requires additional effort beyond the “Report Card” approaches
described in the Scoping Plan.  Such methods need to  include an
analysis of the uncertainties in the GHG emissions, and independent
verification of the bottom-up inventories.  There is only a brief
reference to verification based on atmospheric measurements at the
end of the third paragraph in Section IV-D: “Continuous atmospheric
monitoring of greenhouse gases may be useful for determining the
effectiveness of emission reduction strategies and for future
inventory development.”  Such a statement is ineffective and
artificially weak in articulating the true need of such an
activity.

In order to add credibility to the Scoping Plan, I strongly
recommend that the Air Resources Board include an expanded
description on the role of instrumental observations, including but
not exclusive to continuous monitoring and discrete whole air
sampling and improving verification strategies such as the
combination of observations with modeling (vis a vis “top down
inversion” models).  Without such a statement the Scoping Plan if
implemented as stated will not meet the stated goals and actual
progress towards (verified) emissions reductions.