Comment Log Display

Comment Log Display

Below is the comment you selected to display.
Comment 20 for Aliso Canyon Mitigation Program Draft (alisompdraft-ws) - 1st Workshop.


First Name: Adam
Last Name: Scow
Email Address: ascow@fwwatch.org
Affiliation: Food & Water Watch

Subject: Comments on Aliso Canyon Methane Leak Climate Mitigation Program
Comment:
Please find attached cited comments on the Aliso Canyon Methane
Leak Climate Mitigation Program submitted jointly by Matt Pakucko
of Save Porter Ranch, Gary Graham Hughes of Friends of the Earth
and me. 

The comments, without citation, appear below my signature, here.

Thank you for your consideration of our recommendations.

Sincerely,
Adam Scow
California Director
Food & Water Watch

March 24, 2016

California Air Resources Board
Attn: Mary D. Nichols, Chair
1001 “I” Street
Sacramento, CA 95814

RE: Comments on Aliso Canyon Methane Leak Climate Impacts
Mitigation Program

Thank you for accepting these comments on the Aliso Canyon Methane
Leak Climate Impacts Mitigation Program. 

On October 23, 2015, workers at the Aliso Canyon Storage Facility
operated by Southern California Gas Company (SoCalGas) discovered
the well casing leak that became the worst natural gas disaster in
U.S. history. The blowout lasted nearly four months, displacing
more than 15,000 Porter Ranch area residents from their homes,
sickening countless adults, children and pets, and emitting nearly
100,000 tons of heat-trapping methane into the atmosphere. 

SoCalGas must be penalized for these impacts and the California Air
Resources Board (CARB) must design such penalties to reduce
directly the reliance of Los Angeles on fossil fuels and to
increase access by Los Angeles residents – particularly those in
lower income and vulnerable communities – to low-cost, non-fossil
fuel, renewable energy sources. Therefore, we strongly recommend
that CARB revise the Draft Aliso Canyon Methane Leak Climate
Impacts Mitigation Program to effectively meet these objectives. 

SoCalGas has a proven history of placing the community and
environment at risk by failing to repair compromised equipment at
Aliso Canyon.

The terrible impacts of the Aliso Canyon gas blowout are made worse
by the fact that SoCalGas and the California Public Utilities
Commission were well aware of the risks that led to the disaster
and failed to take steps to protect the surrounding community and
the environment. According to SoCalGas, the average age of a well
at Aliso Canyon Storage Facility is 52 years; eight wells at the
facility have been subjected to “internal and external corrosion”
for over 81 years.  SoCalGas operates 114 storage wells at Aliso
Canyon, and over half of them are over 58 years old.  

SoCalGas admitted in 2014 testimony before the California Public
Utilities Commission (CPUC) that “a negative well integrity trend
seems to have developed since 2008,” indicating that well casings
were reaching a breaking point due to their age and high-intensity
use. The company explained that it discovered a 400 pounds per
square inch leak at Aliso Canyon in 2008, and stated the leak was
“indicative of production casing leaks from either internal or
external corrosion where high pressure gas can migrate to the
surface in a matter of hours.”  Integrity failures in two more
wells at Aliso Canyon were discovered in 2013, but the gas was
reportedly not reaching the surface through the leaking wells, but
was migrating through the soil.  Given these severe conditions,
Porter Ranch and the surrounding areas of Los Angeles have been,
and continue to be, at ongoing risk of exposure to leaks from the
Aliso Canyon Storage Facility.

Numerous SoCalGas storage wells are known to have external
corrosion problems or other signs of physical damage.  At Aliso
Canyon, natural gas storage wells show signs of external casing
corrosion at relatively shallow depths in the well casing and at
deeper depths where oil is extracted using fluid stimulation. 
SoCalGas cited the “unknown number of at-risk wells and their
integrity status” as two factors that complicate budgeting and
accounting related to rates set by the CPUC.   The increasing
number of safety and integrity conditions is attributed primarily
to the frequency of use, exposure to the environment, and length of
time wells have been in service.  The clear implication is that
costs to address the system-wide integrity issues could quickly
balloon.

Natural gas storage wells can be damaged down-hole and have what
SoCalGas terms “poor deliverability rates,” meaning that there is
resistance to natural gas injection. SoCalGas has been clearing
this resistance using gravel packing other well stimulation
methods, potentially including high-pressure injections of fluids,
including acids.  

During the gas disaster, the South Coast Air Quality Management
District inspected 16 wells at the Aliso Canyon Storage Facility
with a forward looking infrared (FLIR) camera, and found that 15
wells had leaking valves, fittings and/or flanges.  These leaks
were minor compared to the leak at SS-25, but nevertheless show the
inherent leak risks associated with natural gas infrastructure at
the Aliso Canyon Storage Facility and elsewhere.

The use of offsets and other market-based approaches does not
result in net environmental and social benefits.
 
The proposed Aliso Canyon Methane Leak Climate Impacts Mitigation
Program suggests that one way for SoCalGas to mitigate its releases
of methane is by using “offsets” created by funding projects such
as dairy digesters on some of the state’s agricultural operations.
CARB suggests that this offset mitigation approach exists outside
of California’s current GHG trading/offset program because of the
impact it may have on that program’s trading/offset projections and
allocations. Regardless of whether the proposed offsets occur
within or without the state trading/offset program, any kind of
offset, including the purchase of credits, is a legitimate threat
to achieving real, additional or permanent emissions reductions. 

Offsets allow polluters to avoid the urgent need to stop polluting
by allowing them instead to pay to continue harmful activities with
impunity, while claiming that emissions have been reduced
elsewhere. Moreover, the agenda behind offsets, as is clear here,
too often places priority on cost containment, market efficiency
and ease of polluter compliance, but disregards the true priority,
which is to reduce GHG emissions.

The issue of permanence presents the most egregious problem from
offsets. The dictionary defines permanence as “the state or quality
of lasting or remaining unchanged indefinitely.” However, CARBS’s
understanding of permanence is quite distorted: “Permanent means,
in the context of offset credits, either that GHG reductions and
GHG removal enhancements are not reversible, or when GHG reductions
and GHG removal enhancements may be reversible, that mechanisms are
in place to replace any reversed GHG emission reductions and GHG
removal enhancements to ensure that all credited reductions endure
for at least 100 years.” 

This definition of “permanence” sends the contradictory message
that offset protocols require permanence, but then allows for
situations where permanence can be violated so long as there are
backup mechanisms in place. For example, the Forest Buffer Account
exists for use should a forest used for offsets burn down or be
destroyed by another natural disaster, reversing the offsets
generated. However, what’s left unsaid is that using a buffer
account like this allows the total amount of emissions released to
increase — the reversed offsets release emissions, requiring more
offsets to replace those reversed, ultimately increasing the
aggregate number of credits used and subsequently increasing the
overall amount of emissions allowed. It’s not as simple as a
one-for-one exchange.

Additionally, offsets conflict with the requirement for permanence
when the life of the reductions is only for 100 years, instead of
achieving true permanence. Crediting periods also contradict the
concept of permanence when they only go for 25 or 30 years at a
time. This is, again, not permanent. It is also unclear what
happens after the crediting periods end, or after the 100 years of
“permanence” end. The companies that issue the offset credits might
not exist in 25, 30 or 100 years, and these impermanent crediting
periods bring all of the offsets issued into question. The entire
structure of these offsets presents a significant risk of
large-scale reversal in the future, undoing whatever emissions
reductions might happen and creating no real progress on the very
critical issue of GHG reductions. 

Another problem arises in the methodology for measuring the amounts
of carbon dioxide (CO2) stored in forests, as well as the methods
for calculating emissions reductions from the proposed rice
cultivation offsets. Although both methodologies are problematic,
they share a significant issue in that they use models and
estimates to arrive at the amount of CO2 stored in a forest or the
amount of methane emissions prevented from different rice
cultivation practices. From these estimates, offsets are then sold
for exact amounts of avoided emissions. A modeled estimate does not
equal an exact amount of emissions. It doesn’t add up. 

Issues of additionality also render California’s offset program
invalid. State regulations hold that, "A registry offset credit
must represent a GHG emission reduction or GHG removal enhancement
that is real, additional, quantifiable, permanent, verifiable, and
enforceable [Health and Safety Code §38562(d)(1) and (2)]. Yet time
and again, CARB approves offsets that do not meet this additional
requirement. For example, Burbaker Farm in Pennsylvania built a
manure digester in 2011, using taxpayer funding, to provide
electricity for the farming operation. The owner of the farm is on
record as saying he originally built the digester not for credits,
but electricity. Yet, in 2015 CARB retroactively certified the
Brubaker digester as a GHG offset generator, and California
industries can now take advantage of this facility to continue
their own emissions even though the digester was already in place,
and operating. Likewise, CARB recently approved the 704-acre Pungo
River Forest Conservation Project in North Carolina as a source of
GHG offsets even though this stand of forest was put into permanent
conservation easement in 2003. Seeking already existing GHG
reduction projects across the country to generate offsets in the
state of California means that there are no additional GHG
reductions taking place through the state’s offset program. 

The offset approach is not the only problem. Cap-and-trade is a
regulatory framework that seeks to eliminate the most important
tenets of the Clean Air Act, which is that companies do not have an
inherent right to pollute. Under cap-and-trade policies, polluters
are given a right to threaten public health and the environment, as
long as they pay for it. These schemes essentially create loopholes
that allow polluters to continue dumping and discharging rather
than holding them accountable for pollution.

Trading creates a mechanism where profits determine who is able to
pollute and can actually lead to an overall increase in pollution.
This is because credits that polluters would purchase are difficult
and often impossible to verify. In fact, a recent study of a
European Union cap and trade program found that 80% of credits were
unverifiable. This means that polluters were able to buy credits to
pollute more from other polluters that may or may not have actually
reduced emissions.

Even if the impossible task of verifying pollution credits were
possible, trading creates regional pollution hot spots, as larger
and well-financed polluters will often opt to purchase credits
rather than run pollution-control equipment. This happened with the
Los Angeles air pollution trading programs under the Rule 1610 and
RECLAIM programs in which communicates of color near the City’s
refinery district suffered from increased air pollution when these
facilities purchased emissions credits instead of installing
reduction technologies. 

While proponents of cap-and-trade and offsets tout the regulatory
flexibility benefits of these policies, in reality these policies
allow polluting industries to put profit above the interests of
public health and the environment. We need to strengthen
protections under the Clean Air Act that have worked for decades to
help hold polluters accountable, rather than rolling back some of
the most important public health laws. 

The threats posed by climate change to our public health,
environmental health, communities and livelihoods are permanent and
real, and so must our efforts to stop these threats be permanent
and real — offsets cannot accomplish this. The fact that they
require loopholes, distortions and exceptions to even “work” shows
that offsets are not a solution, but merely a scam.

Digesters are not a solution to environmental problems, including
climate change.

Waste disposal is a problem for all factory farms, with impacts on
wildlife and human health, the health of the waterways surrounding
them and even on microbial development and potential antibiotic
resistance.  In addition to containing methane, a potent greenhouse
gas, the air surrounding factory farms typically includes ammonia,
hydrogen sulfide and particulate matter.  These can lead to a
variety of illnesses, including lung disease, chemical burns to the
respiratory tract and even death.  Anaerobic digestion is focused
mostly on methane production, though it claims to help with some of
the other effects as well. 

At the most simple level, anaerobic digestion happens by adding
microorganisms to animal waste.  The microorganisms digest the
waste, producing “biogas,” mostly a mixture of methane and carbon
dioxide.  The methane, the main component of natural gas, can then
be burned to generate electricity or heat. 

By covering and heating manure lagoons — and installing expensive
machinery — factory farms claim to be able to capture and burn
methane gas, thereby eliminating greenhouse gas emissions and
producing energy. The environmental benefits of manure digesters,
however, have proven elusive — and seem to offer little remedy to
the far-ranging environmental impacts of the factory farms that
feed these machines. 

But, like manure pits without any methane capture system, digesters
may accidentally spill or leak liquid manure and also present
environmental and climate risks from explosions associated with
methane production. A 1.25-million gallon manure digester in
Wisconsin, constructed with more than $3 million in public funds,
spilled 380,000 gallons of manure into nearby waterways in 2013,
then another 22,000 gallons in 2014. The digester then experienced
a major methane explosion.  Faced with the reality of such
dangerous accidents at digesters,    some rural communities have
opposed the construction of digesters.  

Manure digesters don’t capture all of the methane they produce, and
some amount of methane these machines generate escape as emissions.
This “fugitive methane,” as scientists call it, can greatly
offset—or even negate—whatever greenhouse gas reductions digesters
offer.   And when digesters burn methane, they release greenhouse
gases like carbon dioxide and nitrogen oxide, which also causes
smog and public health issues like asthma.  

Even factory farms that safely manage manure during methane capture
still have to manage the huge volume of waste that remains
following the digestion process.  Digesters don’t make the manure
evaporate or disappear; they merely extract methane gas from it. In
fact, if digesters add water to manure during the digestion
process, the total volume of liquid waste may actually increase.  


Additionally, trucking tons of digested manure to surrounding farms
incurs significant environmental costs associated with fossil fuel
use and presents risks associated with spills. For example, in
April 2015 there were at least two reported trucking accidents in
upstate New York in which thousands of gallons of manure were
spilled.  

Manure digesters are an extremely inefficient method of energy
production and would not exist in the United States absent taxpayer
subsidies. Start-up, maintenance and operating costs are often in
the millions of dollars, and digesters often do not generate enough
energy or revenue to be economically feasible.   Therefore, manure
digesters must not be included in the Aliso Canyon Methane Leak
Climate Impacts Mitigation Program.


CARB should require SoCalGas to fund renewable energy projects in
Los Angeles

CARB’s plan should not call on SoCalGas to fund difficult to track
and regulate agricultural methane ‘offset’ activities that may not
reduce overall emissions and would certainly not benefit Los
Angeles’ impacted and vulnerable communities. In order to assure
that all Angelenos have access to clean, renewable energy, CARB
should require SoCalGas to fund the construction of community solar
gardens that serve the low-income residents of the City of Los
Angeles. Constructing these solar gardens would both provide
economic relief to residents and result in a permanent reduction in
the reliance on fossil fuels. 

If combined with California’s net metering program, residents who
have shares in community solar gardens would see a reduction in
their monthly electricity bills. In addition, increasing the amount
of solar generation in the city would displace current fossil fuel
generation. 

The total generation of the community solar gardens constructed by
SoCalGas as part of this mitigation plan should be sufficient to
annually displace more than enough fossil fuel generation to
account for an equivalent amount of greenhouse gas as was emitted
during the four months of the Aliso Canyon Storage Facility
disaster.

According to the U.S. Department of Energy, less than one-third of
American rooftop space is suitable for solar installation. 
Further, half of all households cannot install a solar PV system
because of issues ranging from ownership, to shading, to lack of
adequate roof space.  Additionally, even though costs have dropped,
installing a rooftop solar PV system still requires upfront
financing that typically hinges on both higher levels of income and
higher credit scores.  While 40 percent of all households in the
United States have income less than $40,000 per year, those
households “account for less than five percent of solar
installations.”  In Los Angeles, less than 40 percent of residents
live in owner-occupied housing. Median household income is below
$50,000 and more than 20 percent of residents live below the
poverty line. 

Community solar enables households that cannot, for financial or
other reasons, to install rooftop solar on their homes and get the
benefits of distributed solar. Community solar programs allow
households to buy a share of the solar electricity generated at a
larger-scale solar garden built in their community.  The
participants in the project receive a share of utility bill
credits, tax incentives and production incentives.  The bill
credits work in the same way that an individual household with net
metering receives credits. For the amount of electricity sold into
the grid by the project, participants receive a payment for the
kilowatt hours represented by their share.  The payment then
reduces their utility bill. 

Conclusion 

Given the aging and deteriorating nature of its infrastructure and
the inherent dangers of natural gas storage to neighboring
communities, a true long-term mitigation plan for the Aliso Canyon
Storage Facility would require its permanent decommission.
Therefore, CARB’s Aliso Canyon Methane Leak Climate Impacts
Mitigation Program must be viewed more accurately as a penalty
against SoCalGas for the harms to the local community and the
environment caused by the four-month leak disaster. CARB’s plan
should focus exclusively on requiring SoCalGas to fund projects to
permanently reduce methane emission in Los Angeles communities. We
urge CARB to revise its draft plan to require SoCalGas to spend its
mitigation funds solely on the construction of community solar
farms sufficient to annually displace more than enough fossil fuel
generation to account for an equivalent amount of greenhouse gas as
was emitted during the four months of the Aliso Canyon Storage
Facility disaster. Any other mitigation activities should be
stricken from CARB’s plan. 

Sincerely,

Adam Scow
California Director, Food & Water Watch

Matt Pakucko
President, Save Porter Ranch

Gary Graham Hughes
California Advocacy Campaigner, Friends of the Earth




Attachment: www.arb.ca.gov/lists/com-attach/22-alisompdraft-ws-WipSO1QnByACYVQm.pdf

Original File Name: PORTER RANCH COMMENTS final.pdf

Date and Time Comment Was Submitted: 2016-03-24 12:13:59



If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.


Board Comments Home

preload