Comment Log Display

The plan must not rely on more reductions through cap-and-trade
than currently realized because those reductions cannot be relied
on as confidently as regulations. In particular, the plan cannot
rely on unfunded incentives.
In addition, cap-and-trade creates huge environmental justice
co-benefit issues, because it allows polluters such as refineries
to continue to pollute and poison disadvantaged communities.
You must increase requirements and enforcement of elimination of
fugitive methane emissions. While you are doing that, cap-and-trade
must be expanded to include fugitive methane emissions, especially
landfills and oil and gas operations and transmission. Currently
cap-and-trade only includes delivered gas of which nearly all is
transformed into CO2.  But the fugitive emissions are directly
releasing methane at 84 times the impact of CO2 over the next
crucial 20 years. In fact, reducing methane emissions has the
greatest short term impact of any climate measure.
Finally, you must upgrade the methane inventory to include the
latest work from the JPL and other detection work. For example, the
2020 Guha, et al. report: Assessment of Regional Methane Emission
Inventories through Airborne Quantification in the San Francisco
Bay Area https://dx.doi.org/10.1021/acs.est.0c01212, shows that
refineries emitted 900% more methane than in the BAAQMD inventory,
landfills 123% more, wastewater treatment plants 100% more, and
composting facilities previously estimated at zero were emitting 11
Gg per year. See attached spreadsheet.