Comment Log Display

 
Citizens for Responsible Oil & Gas, Ventura County
www.cfrog.org

October 30, 2015

To the California Air Resources Board (CA ARB),
 
Citizens for Responsible Oil and Gas (CFROG) supports the adoption
and widespread use of a more scientifically-defensible methane GWP
value that is consistent with methane’s expected lifespan in the
atmosphere. Since methane does not remain in the atmosphere for 100
years, it is not reasonable for CA ARB to continue using a methane
GWP based upon a 100-year interval. Even use of a 20-year methane
GWP is questionable, given that methane has an approximate
atmospheric half-life of 7 years and a generally stated lifespan of
12 years. CA ARB use of a 10-year interval methane GWP makes the
most sense to us, as such use would comport CA ARB policy with the
actual science concerning methane and provide California with a
strong, short-term policy lever to control the progression of
global warming. Such a policy lever may be essential in the near
future to help prevent the onset of positive climate change
feedbacks that might dramatically accelerate the warming of our
planet.
 
In any case, CFROG believes strongly that polluters should be
required to pay for the methane pollution they generate, based upon
a methane-into-CO2-equivalency conversion algorithm that
incorporates a  10-year interval methane GWP (at best) or a 20-year
interval methane GWP (at worst).  Whatever methane GWP constant is
used should be based upon the most recent IPCC GWP values.
 
CFROG believes that these requests are reasonable and prudent for
the following reasons.

1: Use of a 10-year methane GWP would promote a much more rapid
reduction in annual methane emissions than continued use of a
long-interval methane GWP. Annual methane emissions need to be
reduced as quickly as possible if we are to slow down the rapid
rate of planetary warming that is occurring. The IPCC (AR5th, 2013)
has concluded that at the 10-year timescale, the current global
release of methane from all anthropogenic sources will exceed
(slightly) all anthropogenic carbon dioxide emissions as an agent
of global warming; that is, methane emissions will be as
significant as carbon dioxide emissions in driving the rate of
global warming in the near future. At the 20-year timescale, the
IPCC notes that total global emissions of methane will be
equivalent to over 80% of global carbon dioxide emissions. [Source:
Intergovernmental Panel on Climate Change, Climate Change 2013: The
Physical Science Basis, page 719, Figure 8.32,
https://www.ipcc.ch/report/ar5/wg1/]

2: The rationale for using a short-interval methane GWP is provided
within the CA ARB Draft SLCP Reduction Strategy document itself:
"Climate change is no longer a problem to be defined simply in
terms of a legacy we leave to our grandchildren or impacts in the
year 2100. It is affecting us now, and will only accelerate in our
lifetime. Due to the urgency of the issue, and the need to
recognize the costs and benefits of addressing it immediately, we
use 20-year GWPs in this report to quantify emissions of SLCPs."
[See page ES-6.]


The rationale is also supported by recent actions taken by the
California Legislature and Governor Brown. The State of California,
in AB 1496, has now officially acknowledged the importance of
considering the heat-trapping impacts of methane over a
much-shorter timescale: “The people of the State of California do
enact as follows: SECTION 1.  The Legislature finds and declares
all of the following: (a) Methane is . . . an extremely potent
greenhouse gas, with 20 to 30 times the warming power of carbon
dioxide over a 100-year period and more than 80 times over a
20-year period.”

 For these reasons, CFROG recommends that CA ARB adopt a yr2013
Intergovernmental Panel on Climate Change (IPCC) 10-year interval
methane Global Warming Potential (GWP) constant for use in all
annual, short, and mid-term interval methane-to-CO2 equivalency
conversion calculations.
 
CFROG further requests that CA ARB require the use of the most
current IPCC 10-year interval methane GWP constant in all of its
various programs (cap and trade [c&t], compliance offsets under
c&t, greenhouse gas [GHG] inventories, existing compliance offset
protocols under c&t, future compliance offset protocols that have
been proposed for incorporation into c&t, pollution permits, etc.)
with regard to all annual, short, and mid-term interval
calculations, analyses, and emission values.
 
CFROG repeats for the record: methane polluters should be taxed or
fined for the methane pollution they generate, with the tax or fine
based upon a methane-into-CO2-equivalency conversion algorithm that
incorporates a 10-year interval methane GWP (at best) or a 20-year
interval methane GWP (at worst).
 
Sincerely,

CFROG Board of Directors
  John Brooks, Carol Holly, Helen Conly, Rain Perry, Todd Shuman
Policy Advisors to CFROG
  Steve Colome PhD, Leif Dautch LLP, Kevin & Theresa Hartigan,
Richard Holly LLP, 
  Mary Ann O’Connor, Sarah Otterstrom PhD, Vickie Peters, Tomas
Rebecchi, 
  Diane Underhill, C Tom Williams PhD