DATE:  		03/24/2016 
		
TO:		Honorable Mary D. Nichols, Chair
		California Air Resources Board, 1001 "I" Str., Sacramento, CA 95812
		http://www.arb.ca.gov/research/aliso_canyon_natural_gas_leak.htm
http://www.arb.ca.gov/lispub/comm2/bcsubform.php?listname=alisompdraft-ws&comm_period=1

CC:		Kyle Graham, Senior Attorney, Legal Office
		916-445-5515   Kyle.Graham@arb.ca.gov

FROM:		Dr. Tom Williams,  Snr.Techn.Adviser
		Citizens Coalition for a Safe Community

SUBJECT:	Aliso Canyon Climate Impacts Mitigation Program
RE:	           	Comments 

Thank you for the opportunity to provide comments regarding the California Air Resources Board (ARB) proposed Mitigation Program.  We have been dealing with the continuing Aliso Canyon/Porter Ranch issues almost six months and are quite concerned that the LACity, LACounty, and some State agencies and Southern California Gas Company (SCGCo) are approaching the effects of the LEAK as a simple "wasting of mineral resources" and anticipating the "value" of the LEAK as equal to the current cash value of the gas to SCGCo customers. We are highly supportive of a more comprehensive Mitigation Program for the immediate effects, mid-term effect on California's Sustainability Efforts, and the long-term effects on global warming, El Nino(s), and increasing aridity of California's climate. 

We are approaching the "Mitigation Program" from the simple perspective of both mitigation and compensation measures for the immediate, mid-term, and long-term effects through development of a new sustainable community and the LEED Platinum certification of the affected Porter Ranch/Granada Hills community with community, commercial, residential, and infrastructure/services measures.  The San Fernando Valley has few livestock methane generating facilities but have a major solid wastes facility, Sunshine Canyon Landfill which is incorporated into our comments.

We also recognize that the Porter Ranch and Granada Hills communities and the affected area has joined a long list of disadvantaged communities suffering from congested industrial, oil&gas, and urban air pollution.  We have attempted to include measures which can be developed and expanded to serve the I-5 corridor within the San Fernando Valley through programs to take advantages of economies of scale and initiation and development of sustainable measures through a recommended charter high school to promote diverse education of future leaders to help in the longer term mitigation and compensation projects within the Mitigation Program.

Our comments are included in more details below.

Again Thank You for this Opportunity 

Dr. Tom Williams
Citizens Coalition for a Safe Community

TW Background:
PhD and Bachelor in Geology and Zoology, Masters in Zoology
Professor at UC-Davis and Calif.St.Univ.SF in Geology, Instructor UCBerk. in Environmental Conservation
Engineer, Scientist, Environmental  Specialist - 30+ years with URS an Parsons Corp.s and 
	10+ years with Dubai Govt. and companies; Retired 10+ years
Preparation, management and review for 400+ EIRs, EISs, and EAs, worldwide

Comments Background Assumptions: 
Two FaceBook pages "Porter Ranch Gas Leak" and "Save Porter Ranch Forward" have been compiling comments from residences and participants affected by the Aliso Canyon Release for many weeks. 

The Source -- 
The ARB, DOGGR, SCAMD, and SCGCo have all recognized that the LEAK occurred on the pad and in close proximity, and through the Well SS-25 (API# 03700762) and not through any other areas as was claimed by some in November 2015.  No samples or tests have ever been made or released as to the LEAK gas compositions, temperatures, or pressures during the entire LEAK period (110+days).  Assumptions have been made as to the composition and flows but without direct evidence from the LEAK.

Financials --
For the purposes of these comments, we have assumed a total compensation/mitigation package of more than $400,000,000; 
	to be placed into a fund 
	then paid out over a 3-5 year period with interest and 
additional funding in the future for initial and short term administration, design, contracting, and installation/startup and 
then for mid-term ongoing operations, maintenance, and administration/reporting to demonstrate achievement of mitigation
Effects and costs and penalties must be considered similar to a cumulative financial net-present value calculation as to the immediate, short-term, mid-term, and long-term costs and effects.
 
The impacts of methane on global climate change from global warming and greenhouse gases must be assessed based on their initial (1-5years), then mid-term (6-25years), and long-term (25-100years) effects.  Other estimates  based on loss of revenues from loss sales of gas to customers is not relevant to the Mitigation Program and the long term effects of greenhouse gases.

Affected Area -- 
Although by definition Global Warming and Greenhouse Gases are assumed to affect the entire globe and especially the western Pacific area (e.g., the strange El Nino of 2015-16), California and especially Southern California have received the greatest direct and immediate impacts, and such have been acknowledged by the Southern California Gas Company (SCGCo), Los Angeles County (LACo), the State of California, and the many state, regional, and local agencies and jurisdictions.  Although delineations are not currently available, the most affected area has involved the central and northwesterly portions of the North San Fernando Valley from SR-27   to I-5/I-405 and generally referred to as Northridge, Porter Ranch, and Granada Hills.  The Mitigation Program must include all residences which LACo and SCGCo have acknowledged as affected as demarcated from those properties subject to relocation by any agency and the SCGCo to the LEAK, Well SS-25. 

For these comments we have assumed an area including 10,000 single family dwellings of two story with 3000+sqft (total floor area of 300M sqft) with roof space of 1500+sqft  (45x35ft) and total area of about 750 acres (30Kx16Kft), along with 10% commercial floor areas of 30M sqft (e.g., Rinaldi Commercial Malls), and 10% institutional/community floor area, 30Msf.  Some additional undeveloped area (1000acres) lies north of Sesnon Ave. and the SCCGCo boundary for the Aliso Canyon Gas Storage Facilities in LACo. 

A Granada Hills has been affected and families have been relocated by SCGCo we have also included in the Mitigation Program: the Sunshine Canyon Landfill and the operating Cascade Oil Field, about 3.5mi east of the LEAK.

Comments:   Our approach is to focus comments in support of a single Umbrella Approach of being the first ever "LEED" (Leadership in Energy and Environmental Design) "Platinum Certified" "Community" (affected parts of Porter Ranch District and Granada Hills of the City of Los Angeles) with all aspects generally to specifically covered, in time available.

LEED certification at a Platinum for the affected Community of Porter Ranch and Granada Hills shall be fully and totally funded by SCGCo without requirements for joint funding of some projects beyond the demarcated affected area for disadvantaged communities adjacent to the affect areas.

LEED reviews emphasize integrative nature of the conservation processes and this approach has posed some great challenges for also meeting ARB goals and objectives and guidance to achieve such.  ARB guidance through the draft Mitigation Program report emphasizes energy and methane as the primary if not sole target of the Program and funding. Direct and indirect measures related to water, landscaping, and biotic resources have been largely avoided based on the Program guidelines.  Comments have been focused largely if not totally on the energy and fuel uses rather than a more integrated environmental approach.

Mitigation Program Projects/Measures:

Direct Methane Mitigation Measures:
The ARB goals clearly indicate that the proposed measures shall directly or in-directly:
•	reduce methane emissions sufficient to compensate for the effects of the short-term release from the Aliso Canyon well blowout, and 
•	long-term effects from the short-term large release. 
Herein Direct Measures are assumed to eliminate/greatly reduce use of methane in 10,000 residences and say 500 commercial structures and to eliminate/greatly reduce generation and/or emission of methane from the Aliso Canyon and Cascade oil/gas fields/facilities and from the Sunshine Canyon Landfill. 

Immediate and Short Term: 
Oil and Gas Measures.   Through DOGGR and SCAQMD, ARB must include an immediate (2016-2017) program of limiting current methane and related hydrocarbon leaks from all well head, gathering lines, and related surface facilities for the SCGCo Aliso Canyon Gas Storage Facility, the Termo and other company's Oat Mountain and Del Aliso, a section of Aliso Canyon, Oil and Gas Production Field, and the Cascade Oil Field (Granada Hills).  Current leaks are identified as minor, major, and violation based on criteria of 1000, 10,000, and 55,000ppm gas emissions without flow, pressures, and temperatures, respectively.  Such leakage criteria must be reduced to violation at levels >1000ppm and estimated flows of >1000cuft/day.  As leakage can and has occurred from abandoned, plugged, and idle wells, all wells and their gathering lines and related surface facilities must be inspected and tested on  a quarterly basis for two years and annually thereafter achieving the criterion levels.  Any leak above the criterion levels must be repaired and pass subsequent inspection and monitoring.  The three fields include more than 300 wells which must be inspected/tested and limited before December 31, 2017 and therefore adequate time is available for inspection of the three fields at a rate of 10-12/month.  Detailed calculations as to the reduction can best be estimated once a representative sample has been inspected; a target equivalent of 5% of the total Leak volume is assumed. 

Landfill Measures.  Through the LACo and related agencies, ARB must include an immediate program (2016-2017) of limiting generation and emission of untreated methane from the surface and perimeter of the Sunshine Canyon Landfill (480acres, 7000x3000ft and 20,000ft perimeter). A surface survey using currently available technology may be augmented by aerial surveys in order to identify the magnitude and locations of the emissions in relation to current facilities and operations and a mitigation project designed and implemented by January 2018 for total implementation period not to exceed 24 months.  Periodic surveys must be conducted to assure mitigation and quantify mitigation levels, with a target equivalent to a total 10% of the total LEAK release assumed.

Mid-Long Term: 
All direct measures must be continued in perpetuity and are assumed to become standard practices and incorporated into local and regional regulations. Few indirect measures are considered in the long term other than operations, maintenance/replacements, and administration/monitoring of the shorter term measures.  As new technologies are anticipated during the next five years, all proposed measures must be developed in such manners a to allow and promote upgrades to initial an later deelopments or redevelopments of the shorter term measures.

In-Direct Methane Mitigation Measures:
Indirect Measures would be those which would reduce the residential, commercial, and community indirect use of methane (e.g., gas-fuelled power plants) and may substitute alternative energy/fuels which would not be produced from methane.  Likewise reduction of organic wastes going to landfills or of milk and meats coming from feedlots and cattle would indirectly reduce the production of methane gases coming from the landfills and feed lots, e.g., a vegetarian, egg-based, and/or non-lactose diet for 10,000 families would indirectly reduce methane arising from feedlots or solar electric powering of 10,000 residences and 500 commercial structures would reduce peak and baseload power use from gas-fuelled power plants and expand use of existing renewable power for pumped storage in the LA County grid, especially to the northeast SFValley disadvantaged communities. 

Immediate and Short-Term (1-5 years)

Indirect Residential Recycle Measures - Solid Wastes - Composter   An onsite composter can directly remove the organic wastes from the passage to the landfills and generation of landfill gases and eliminate any leakage from landfills.  Such an onsite facility can be easily implemented and can provide many economies of scale and prospective improved training for assure performance and use of generated methane 

The composter therefore reduces total energy consumption involved with the containment, transport, and offsite storage/decomposition of the materials, in addition to the more direct use of the gas.

A representative onsite composter unit is as shown below
   HomeBiogas Co.,  homebiogas.com   <$1000 per unit x10,000 units with 4x6x4ft footprint/size  Total $10M  total land area required, 10,000 x 25sqft  = 250K sqft http://l.facebook.com/l.php?u=http%3A%2F%2Fhomebiogas.com%2F&h=WAQEMAzJN&enc=AZPccOqAnA48GPg6TvBn4Fqpn1shHx6HE8tfh6vSBTWI5qmm0_y1Us74BwJOtwaxL8ue5IXItLJZ0NAsFF7ncRkH0fQg7j1r3ef9fzSjsGnCfbksqcmnWos2OiHJ43sQKjVOiZH-ImPXrqNy4FtEGVXBpxcQzv7me-k4sP9S3O6Www&s=1

Indirect Residential Conservation Measures
Change Energy for Hot Water Heating (In and Outside Building)

A.  Electric Hot Water Heaters
Use of electric hot water heaters for residential use has been widespread, and their use is unknown as to the numbers or percentages in the Affected Area.  Replacement of methane hot water heaters would immediately reduce short term use of methane although more methane would be required to generate sufficient electric at a distant power station and to compensate for pipeline and station emissions and to compensate for electricity power line losses of more than 30 miles.

B.  Solar Hot Water Heaters
Replacement or major reduction of gas hot water heaters has been done for several decades using roof top or wall solar hot water heaters with and without gas heaters for backup. Part of this measure depends on the residents' water uses and storage capacity of the solar unit and unfueled hot water storage tanks   

C.  Integrated Solar Water/Building/Pool Heating System
Based on some unique features of the affected area, an integrated hot water system may be able to eliminate both gas-fired water and space heating by interconnecting pool/large-jacuzzis with the solar water heating system and the space heating system using hot water directly or indirectly.  Such integrated systems are used elsewhere in the US and can be installed based on the specifics of the location.  In the affected area, the post 1970 tract-development provides more uniform building layouts, heating systems,  and a large percentage of residences with large water/heat storage systems (e.g., pools/jacuzzis) which in turn will ease the development of standard integrated designs and economies of sscale not practical in other US areas.  

Indirect Commercial Recycle Measures - Solid/Food Wastes - Commercial Composter
A mall-sized/located composter can directly remove the organic wastes of restaurants and markets from the passage to the landfills and generation of landfill gases and eliminate any leakage from landfills.  Such an onsite facility can be easily implemented and can provide many economies of scale and prospective improved training for assure performance and use of generated methane for onsite purposes. 

The residential sized composter can be substituted by simple additions or a unit may be enlarged to fit the probably size required by approximately 50 potential sites in commercial malls of the affected area. Such commercial sizing and multi-unit would reduces total energy consumption involved with the containment, transport, and offsite storage/decomposition of the biogas fuel materials, in addition to the more direct use of the gas.  Similarly by providing an optimal commercial unit, the prospective market for the manufacturers may be greatly expanded for the entire LACounty and beyond. 

A representative onsite residential composter unit is as shown below and would be converted to commercial purposes by ways of adding units or working with the manufacturers for developing more optimally sized units or combination.
   HomeBiogas Co.,  homebiogas.com   <$1000 per unit x10,000 units with 4x6x4ft footprint/size  Total $10M  total land area required, 10,000 x 25sqft  = 250K sqft http://l.facebook.com/l.php?u=http%3A%2F%2Fhomebiogas.com%2F&h=WAQEMAzJN&enc=AZPccOqAnA48GPg6TvBn4Fqpn1shHx6HE8tfh6vSBTWI5qmm0_y1Us74BwJOtwaxL8ue5IXItLJZ0NAsFF7ncRkH0fQg7j1r3ef9fzSjsGnCfbksqcmnWos2OiHJ43sQKjVOiZH-ImPXrqNy4FtEGVXBpxcQzv7me-k4sP9S3O6Www&s=1

Indirect Commercial Conservation Measures
Change Energy for Hot Water and Heating (In and Outside Building)
A.  Electric Hot Water Heaters
Use of electric hot water heaters for commercial use has been widespread, and their use is unknown as to the numbers or percentages in the Affected Area.  Replacement of methane hot water heaters would immediately reduce short term use of methane, although more methane would be required to generate sufficient electric at a distant power station and to compensate for pipeline and station emissions and to compensate for electricity power line losses of more than 30 miles.

B.  Solar Hot Water Heaters
Replacement or major reduction of gas-fired commercial hot water heaters has been done for several decades using roof top or wall solar hot water heaters with and without gas heaters for backup, especially in the laundry and other high volume hot water uses.  Part of this measure depends on the commercial water uses and storage capacity of the solar unit and unfueled hot water storage tanks.   

C.  Integrated Solar Water/Building/Pool Heating System
Based on some unique features of the affected area, an integrated hot water system may be able to eliminate both gas-fired water and space heating by interconnecting pool/large-jacuzzis with the solar water heating system and the space heating system using hot water directly or indirectly.  Such integrated systems are used elsewhere in the US and can be installed based on the specifics of the location.  In the affected area, the post 1970 tract-development provides more uniform building layouts, heating systems,  and a large percentage of residences with large water/heat storage systems (e.g., pools/jacuzzis) which in turn will ease the development of standard integrated designs and economies of sscale not practical in other US areas.  

Indirect Community Measures.
Community measures include two general categories: schools and large more centralized community structures and dispersed small service facilities but the most direct and larger measures must be directed at higher fuel/energy use buildings.  As many institutions and organizations are changing from a more seasonal use scheduling to year-around operations, the community measures assume year-around operating schedules rather than a more focused, temperate scheduled operations.  Such operations require considerations of both cool-dark and hot-sunny periods with differing combinations of heating/chilling/lighting. 

Based on the eventual year around operations and their energy needs and availability, a core element for all uses is integrated internal/external temperature/lighting/wind sensor and operating system (e.g., interior "climate controls").  Sensor/program systems for automated awnings, window, and reflective light modifying systems for exteriors facilities and improved interior motion/temperature/incidental lighting are currently available and must be assumed as immediate-short term core elements for all other measures.  

Mid-Long Term Conservation Measures
Charter High School for Porter Ranch for Sustainability Research...
O&M/Adm$$s have to be included in the Mitigation Program
Similar or parallel to:  Southeast Weatherization and Energy Efficiency Training (SWEET) Center, 
A prime example of adaptive building reuse, this facility was previously a diaper laundry and an autobody shop. In early 2010, Southface undertook an extensive renovation to the building, equipping it to house the organization's growing number of weatherization and green building classes, workshops and other training programs. As a result of the renovation, the SWEET Center qualified for an EarthCraft Light Commercial green building certification, with significantly improved energy performance results.
Located at Piedmont and North Avenues in downtown Atlanta, Georgia just blocks away from the award-winning Southface Eco Office, the SWEET Center welcomes thousands of building science trainees annually.
It provides practical, hands-on learning opportunities, teaches up-to-date weatherization techniques and testing protocols, and provides access to test equipment like blower doors and infrared cameras, as well as air sealing props, combustion appliance and duct leakage testing, and insulation installation opportunities.
The SWEET Center is one of a small number of training centers in the nation to become an Interstate Renewable Energy Council (IREC) Accredited Training Provider for our Energy Auditor, Quality Control Inspector, Retrofit Installer Technician and Crew Leader Training Programs. Upon successfully completing any of these training programs, graduates meeting pre-requisites are prepared to challenge the nationally recognized Home Energy Professional Certification exams from the Building Performance Institute based on Standard Workforce Specifications developed by the National Renewable Energy Laboratory (NREL) and the U.S. Department of Energy (DOE).
Exposed roof area is covered with a green roof in an effort to provide a seamless integration of the new building to the existing environment and thus enhance local biodiversity. Taking this into consideration, rainwater harvesting was introduced as a sustainable solution to reduce potable water demand not only for irrigation of the extensive landscape areas but also for toilet flushing.
Creating high quality indoor spaces was top priority. Thanks to the unique project design there is sufficient daylight penetration in all regularly occupied areas, which not only significantly reduces lighting loads but also creates a high-quality indoor environment for the school.
Indirect Long-Term Community Conservation Measures
Some methane use could be mitigated by CO2 biotic-fixing activities and soil augmentation by conversion of existing introduced annual grasslands of the degraded southerly-facing slopes of the SCGCo's Aliso Canyon and Oat Mountain fields/facility. Existing grasslands replaced earlier annual shrubs/herbaceous vegetation almost 200 years ago, and with assistance of appropriate historians and botanists, appropriate LACo staff can develop and implement a revegetation plan over the long-term period upto 2040.  An order of magnitude estimate involves planting of 1000 acres (43,600,000 sqft) with 10M plants and thereby requiring a long-term native plant (e.g., 15 different sages) nursery at the site. Simple estimated change in CO2 would be at least double existing annual grass conversion production.

In-Direct Long-Term Conservation Measures - Disadvantaged Communities
Methane-fuelled electricity can be reduced by solar-generated power substitution for existing and increased pumped-storage generation of power system electrical use by increased solar power from affected residential and commercial areas.  Such increased pumped-storage generated electricity and excess solar-supported for the I-5 corridor disadvantaged communities.  Costs of pumped storage generation are less in capital and operating/"fuel" terms and electricity for the I-5 corridor would have at least 30% lower costs for delivery  and reliability; such lower costs could be directly or indirectly passed along the disadvantaged communities. 

General InDirect Methane Measures:
Replace DWP Electric with Local InGrid Solar Electric Panels and Microturbines
Replace DASH/Access Diesel and CNG buses with electrical/battery

Provide 
More pedal and electric bike lanes and bike infrastructure
Improved walking routes (e.g. green alleyways)

Plant more trees to increase canopy to reduce heat island effect and purify air. 
Use greywater for all landscape irrigation including golf course. 
Don't disturb (develop) or limit to develop slopes over 15% site. 

New green spaces likes parks or pocket parks (on underutilized land)
New trees / replacing of dead trees on sidewalks or medians
Community gardens to grow vegetables and sidewalk vegetable boxes

Develop Green alleyways, Green walls, and Green roofs.
Install PV panel shades for parking. 
Require all new commercial buildings to be LEED platinum.