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 and Liz Anthony have continued to meet with senior CARB staff to discuss the 2030 Scoping Plan and adoption of climate targets for the electric sector as a whole and for each load-serving entity (LSE). CEERT has urged CARB to use the Scoping Plan and the LSE targets to guide implementation of SB 350’s provisions on integrated resource planning at the California Public Utilities Commission, and at the California Energy Commission for publicly owned utilities.

CEERT emphasized the importance of transparent, real-time GHG accounting to complement and protect against GHG emission increases from regional grid expansion, and the need to track and report on criteria air pollutants from California’s natural gas plants in order to ensure that emissions in environmental justice communities do not increase, or are mitigated. We discussed the need to develop a declining cap on natural gas power plant emissions, as a way to ensure continuing reductions in such emissions in disadvantaged communities, and to chart an orderly pathway to reducing California’s dependence on gas-fired power plants for ancillary services, flexible capacity, and grid reliability.

Short-Lived Climate Pollutants (SLCPs)

The CARB Board adopted the final version of its Short Lived Climate Pollution Reduction Strategy at its March 23 hearing in Riverside.  CEERT spoke in favor of the SLCP Strategy, which seeks to reduce the state’s emissions of short-lived climate pollutants such as methane, black carbon and hydrofluorocarbons (HFCs), all of which are more potent at trapping heat than carbon dioxide, though they remain in the atmosphere for a much shorter time.  Reducing these super-pollutants will have a more immediate impact on fighting climate change while also reducing harmful air pollutants such as nitrogen oxides and particulate matter.  The Strategy sets reduction targets relative to 2013 levels of 40 percent for methane; 40 percent for HFCs; and 50 percent for black carbon emissions by 2030.

Livestock, landfills, and the oil and gas industry are the state’s major sources of methane.  The SLCP Strategy requires the capture of methane from manure at large dairies and the reduction of methane emissions from enteric fermentation.  Emissions from landfills will be cut significantly by reduced disposal of organics in landfills.  Methane emissions from the oil and gas industry will be reduced through a new regulation that targets methane leaks from oil and gas operations (see below).

While California has already reduced black carbon emissions from anthropogenic sources by 90 percent since the 1970s—largely through stringent regulation of diesel emissions—the SLCP Strategy will rely on greater deployment of zero-emission vehicles for on-road use, in ports, and at rail yards. The Strategy also relies on the increased use of mass transit (especially using zero-emissions technology), and seeks to reduce black carbon emissions from residential wood-burning appliances.

HFCs are used in refrigeration and air conditioning, as propellants, and in the manufacture of insulation.  CARB is studying HFC substitutes, which are becoming increasingly available, to better understand how they can be introduced into the market with minimal cost and disruption.  CARB’s evaluation will undergo a third-party review before it develops any regulations requiring the replacement of HFCs. 

CEERT has been advocating for the state to undertake an SLCP Reduction Strategy for more than a decade, and thus is gratified to see California finally adopt such a strategy.  With the latest assessment indicating that current proposed global actions remain insufficient to avoid global warming greater than 2°C (3.6°F), it is critical that California expand its efforts to reduce all climate pollutants.   While the state continues to explore ways to achieve deeper CO2 reduction targets through the CARB Scoping Plan process, adopting a strategy to pursue SLCPs is necessary to provide a climate buffer until global efforts to curb emissions of long-lived climate pollutants can take effect.  Achieving near-term SLCP emission reductions will also improve air quality and health in vulnerable communities. 

Oil & Gas Rule
On March 23 the CARB Board adopted what are likely the most comprehensive set of regulations of methane leaks from the oil and gas industry.  The regulations include changes to the Oil & Gas Rule for which CEERT and other parties had long been advocating, such as a requirement for quarterly monitoring of methane emissions from oil and gas wells, gas processing facilities, compressor stations, and other processing and delivery equipment.  Some equipment will also be required to add vapor collection systems. 

CEERT spoke in favor of the Rule, which is a critical component of the SLCP Reduction Strategy and is expected to reduce methane emissions from the state’s oil and gas operations by the equivalent of nearly 1.4 million metric tons of CO2 annually.  Avoiding these leaks will also reduce smog-forming chemicals and volatile organic compounds such as benzene that are air toxins.