Advocacy at the California Air Resources Board (CARB)

Part 3 CA State Code

California’s landmark Global Warming Solutions Act of 2006 (AB 32) requires close collaboration by the Air Resources Board, Public Utilities Commission, Energy Commission, and Independent System Operator to plan and implement the reduction of greenhouse gas emissions in California back to 1990 levels by 2020. To help guide this process, CEERT developed a forecast of what success in this effort might look like in our “2020 Vision” analysis. We also sponsored a symposium of some of the world’s leading climate scientists on how to improve on the climate targets in the Kyoto protocols.

Recent Developments:

V. John White met with senior CARB staff to discuss adoption of electric-sector climate targets to guide CPUC implementation of SB 350’s provisions on integrated resource planning; the need for accounting, tracking, and mitigation of potential increases in GHGs and in-state natural gas pollution in the context of regional grid expansion; renewable hydrogen, storage, and carbon capture with fuel cells; and methane emission reduction strategies such as incentives for digesters and production and utilization of renewable bio-methane.


Short-Lived Climate Pollutants (SLCPs)

CEERT took part in meetings of the California Environmental Dialogue, a group of California business and environmental stakeholders, and officials from CARB and the U.S. Environmental Protection Agency to dis­cuss recent developments on short-lived climate pollutants.  CARB gave an overview of its pro­posed scoping plan to reduce emissions of methane, black carbon and F gases, and discussed proposed funding for methane digesters.  We met with CARB staff to discuss strategies for GHG-reduction funding and market incentives for construction of new methane digesters and expanded use of bio-methane.

CEERT submitted comments on CARB’s draft of its Proposed Short-lived Climate Pollutant Reduction Strategy jointly with Californians against Waste, Natural Resources Defense Council, Sierra Club of Cali­fornia, San Francisco’s Department of the Environment, and other organizations.  Those comments con­tin­ued to support CARB’s goal of reducing methane emissions 40% by 2030 by diverting almost all or­ganic materials from landfills by 2025 and reducing methane pollution from California’s dairies, waste water treatment plants, and oil and gas industry.  Methane is the second largest contributor to global warm­ing, and over a 20-year period is roughly 85 times more powerful than CO2 at warming the climate.

CARB staff are currently evaluating stakeholders’ written input and oral testimony on the Proposed SLCP Reduction Strategy and plan to release the final Strategy for stakeholder review in the fall.

CEERT supported CARB’s July 21 adoption of its new oil and gas (O&G) regulations, which seek to re­duce GHG emissions from the state’s O&G industry.  The regulations require regulated entities to take actions to limit intentional (vented) and unintentional (leaked or fugitive) emissions from active and idle equipment and operations—e.g., emissions that could be previously vented must now be col­lected or avoided.  Research indicates that depending on the end use (e.g., power generation or transportation), an aggregate annual average leakage rate of 2-3% negates any climate benefit from using natural gas.

Though their focus is GHG mitigation, the regulations should also deliver con­siderable air quality co-benefits by eliminating thousands of tons of criteria pollutants, especially volatile organic com­pounds.  De­spite California’s efforts to clean up climate and air emissions from its O&G industry, the state still im­ports about 90% of its natural gas (NG) from out of state.  CEERT therefore rec­om­­mended that CARB work closely with the U.S. EPA’s implementation of President Obama’s Climate Ac­tion Plan to ensure that O&G methane emissions outside the state are maximally reduced, and below the 2-3% threshold.

In early June, CARB, the CPUC and the CEC convened a joint two-day symposium ( on addressing fugitive methane emis­sions from California’s NG system.   The symposium brought together state and federal regulators, O&G industry representatives, researchers, tech­nology providers, industry consultants, and NGOs.

CEERT’s John Shears was part of the symposium’s closing panel on policies for reducing O&G in­dus­try emissions.  He stressed methane’s role in creating background ozone (UNEP and WMO attribute about two-thirds of the rise in global levels of tropospheric background ozone to meth­ane pollution), and the co-benefits of lowering California’s methane emissions.  Shears recommended that CARB and federal agen­cies regulate methane as an important air pollutant, not just as a climate pollutant, and that they work together to tighten oversight of emissions from the entire U.S. NG system.  He stressed that for NG to be truly effective as a bridge fuel to a near-zero-carbon future, industry and regulators would have to main­tain aggregate average annual system-wide NG emis­sions below the 2-3% threshold.  Tim O’Connor of CEERT affiliate Environmental Defense Fund highlighted similar points on a panel earlier in the day