California Gas (SoCalGas) has criticised a draft state government plan over how the natural gas provider should mitigate the methane leaked at its Aliso Canyon facility, pushing for the estimated amount of GHGs emitted to be slashed by some 70% in a bid to reduce the clean-up costs.

SoCalGas has pledged to offset the climatic damage caused by the four-month leak, which was finally plugged in February, but has taken issue with a number of the recommendations made by the California’s Air Resources Board (ARB) in a program it drew up at the request of Governor Jerry Brown.

The company outlined its concerns over the plan in a Mar. 24 letter to ARB Chair Mary Nichols from SoCalGas regional vice president for external affairs and environmental strategy George Minter that has been published on ARB’s website.

In particular, Minter argues that any calculations should be based on methane’s global warming potential (GWP) over a 100-year timeframe, rather than the 20-year time horizon that ARB used.

“Using the 20-year GWP in this situation is inappropriate as well as contrary to California and federal law.  Therefore we do not intend to use [it] as we evaluate mitigation projects,” he wrote.

The US Environment Protection Agency has assigned methane a 20-year GWP value of around 80, and a 100-year GPW value of around 25.  This is because methane molecules lose their heat-trapping capacity over time, sticking around in the atmosphere for a relatively shorter period than carbon dioxide.

ARB has estimated that around 100,000 tonnes of methane were unleashed during the leak, which would equate to around 8 million tonnes of CO2 under the 20-year GWP.

However under a 100-year horizon, SoCalGas said the figure would be closer to 2.4 million, assuming the underlying emissions estimate is correct, a determination the company also claims is premature.

ALLOWANCES & OFFSETS

In its program, ARB proposed that as its primary emphasis, the portfolio of projects that receive SoCalGas funding should target methane from the agriculture sector, including the dairy industry, and from the waste sector, including landfill and wastewater.

These sectors make up around three-quarters of California’s total methane emissions, and therefore would likely need to be the main target in order to meet the overarching mitigation goal, ARB said.

The agency also ruled out involving allowances or offset credits from California’s carbon market, saying their use would be inappropriate for several reasons including the fact that the reductions would not be additional, and that scheme, with its “carefully calibrated” annual emission caps, was not designed to capture fugitive emissions from sources such as Aliso Canyon.

In addition, ARB claimed that SoCalGas buying compliance instruments to mitigate the leak could impact the cost and ability of entities under the cap-and-trade scheme to comply, a claim which the company said “seems both mistaken and inconsistent” with other aspects of the draft plan.

“It is highly unlikely that SoCalGas’s purchase of allowances or offsets in the [2.4 million-unit] range ‘could tighten the markets’,” Minter wrote, quoting ARB’s draft proposal.

“The combined triennial cap for California and Quebec is in the range of 1.3 billion tonnes. Relative to these massive volumes, an estimated additional demand in the approximate range of only 2.4 million tonnes, or less than 0.2% of the cap, is immaterial.”

SoCalGas added that the recommendation that the mitigation strategy concentrate on agricultural sector emissions is inconsistent with ARB’s stance on prohibiting the company’s use of offsets.

“The [livestock] sector is already covered by the offset protocols currently in effect, [which] offer a transparent and rigorous procedure to mitigate emissions.  Such programs … have a proven track record of delivering additional and permanent reductions in GHG emissions.”

TARGET PROJECTS

In its draft plan, ARB said short-lived climate pollutants such as methane should be targeted by SoCalGas’ funding, and that every effort should be taken to look for project opportunities in Southern California, and more specifically in the areas affected by the Aliso Canyon leak.

The regulator added that the program should also examine ways to promote renewables and energy efficiency or cut reliance on fossil fuels, for example through initiatives to incentivise the replacement of old appliances or subsidies for low- or zero-emission vehicles.

“There is no basis for such a limited approach.  Any mitigation plan should encourage flexibility to pursue an assortment of cost-effective and feasible emission-reduction measures and mitigation projects, even if [they] do not involve methane,” Minter wrote.

“[And] since the effects of climate change are global, the specific location where methane or other GHG emissions reductions occur is irrelevant to their effectiveness in mitigating the impacts of such emissions.  As there are a variety of opportunities to reduce GHG emissions both inside and outside of California, however, the mitigation program should not be artificially restricted to projects within the state.”

ARB also recommended that any emission reductions occur within a defined timeframe, “ideally five and not more than 10 years” from the start of the leak.

But Minter countered that such a timeline is “arbitrary at best, since the GHG reduction benefits of these projects would be ongoing”.

“[It] … means that projects with longer lifecycles would not be evaluated on an equal basis with projects that accomplish those reductions in 10 years, albeit are more costly or resource-intensive.”

Minter said any participation by his company in an ARB program would be voluntary as it “does not itself impose any legal obligations on SoCalGas, [though it] does however, provide ideas.”

An ARB spokesman told Carbon Pulse the the agency “disagrees with SoCalGas’s overbroad assertion regarding fugitive emissions, … [but] anticipates that SoCalGas will follow through on its commitment, [to mitigate them] rather than renege on it.”

He added that the agency’s final mitigation plan will go to Governor Brown this week before being made public, though he was unable to provide a timeline for that.

ARB is among the plaintiffs in a civil lawsuit against SoCalGas, which includes claims that could impose a mandatory mitigation obligation on the company should the plaintiffs win.

By Mike Szabo – mike@carbon-pulse.com