Comment Log Display

On behalf of Wasteful Unreasonable Methane Uprising (WUMU), I, Todd
Shuman, submit the following supplementary comment concerning the
Aliso Canyon Climate Impacts Mitigation Program.

WUMU recommends measures be instituted that require SoCalGas/Sempra
to finance further reductions in methane emissions from
non-livestock-related sources, including pneumatic devices, pumps,
and compressors used within the natural gas industry itself. 

WUMU also recommends that CARB enact a Methane Fee that would be
imposed on all those responsible for atmospheric methane emissions
as a mitigation measure.(Two variants of a methane fee proposal are
provided in the appendix below.)
 

SoCalGas/Sempra shall then be required to subsidize all methane
emission fee payers who would be required to comply with any
methane fee that might be instituted in the near future. WUMU
proposes that this subsidy be 33 percent of total annual methane
fees paid by all those responsible for atmospheric methane
emissions until documented methane emission reductions associated
with methane fee enforcement completely offset the cumulative
methane discharge associated with the Aliso Canyon SS-25 gas
storage well blowout.


Sincerely,

Todd Shuman, Camarillo, WUMU 805.987.8203
 


Appendix: Methane Fee Variants 

A: "All those legally responsible for the generation of more than
40 pounds of uncaptured, unburnt methane emissions per year shall
be required to pay an annual fee on each ton of uncaptured, unburnt
methane emission for which they are responsible. The fee shall be
100 percent of the baseline value of $4700 of damages per ton of
methane (in 2007 dollars) that is presented in The social cost of
atmospheric release, Drew T. Shindell, Climatic Change (2015)
130:313–326, DOI 10.1007/s10584-015-1343-0, page 319, Table 2,
Median total; declining rate."


This approach would result in a methane price per ton paid by those
responsible for methane emission of approximately 4700 dollars per
ton, in 2007 dollars (or 5372 dollars, in 2015 dollars).  (See 
http://www.usinflationcalculator.com/.)


B: "All those legally responsible for the generation of more than
40 pounds of uncaptured, unburnt methane emissions per year shall
be required to pay an annual fee on each ton of uncaptured, unburnt
methane emission for which they are responsible. The fee shall be
based upon a methane-into-CO2-equivalency conversion
algorithm/calculation that incorporates the most recent
scientifically-defensible 10-year interval methane GWP constant (at
best) or 20-year interval methane GWP constant (at worst). The
methane GWP constant used for such calculations should also
incorporate climate-carbon feedbacks."


This approach would result in a current methane price per ton of
approximately 1120 dollars per ton. (Current price of CO2e
[$13/ton] X 86 [20-yr methane GWP, IPCC AR5th]. See
http://calcarbondash.org/.

 
 

















 

(Note: methane traps heat in the atmosphere 86 times as intensely
as carbon dioxide on a pound-for-pound basis, over a twenty year
period.)



 

I recommend additional measures that require SoCalGas/Sempra to
finance reductions in methane emissions from other sources,
including pneumatic devices, pumps, and compressors used within the
natural gas industry itself.