Comment Log Display

May 26, 2016


California Air Resources Board
1001 I Street
Sacramento, CA 95814
Re:	Comments on Proposed Short Lived Climate Pollutant Reduction
Strategy and Draft Environmental Analysis

The Coalition for Clean Air urges the Air Resources Board to
finalize and adopt the Proposed Short Lived Climate Pollutant
Reduction Strategy and begin implementing it as soon as possible.
Reducing these SLCPs, or “super-pollutants,” is essential to
slowing the rapid warming of the planet; in addition, many of the
SLCPs are hazardous to human health at ground level, so curbing
them provides significant benefits to public health. Action by
California can help to spur other states, as well as other nations,
to reduce super pollutants.
During legislative consideration of the California Global Warming
Solutions Act (AB 32, Nuñez/Pavley, 2006) and during the early
years of its implementation, some experts and advocates urged ARB
to take quick and aggressive action, as warranted by scientific
data, to reduce the generation of SLCPs; but, as former Board Chair
Robert Sawyer testified at the May 26 Board Hearing, ARB staff at
that time opposed taking such action. We commend ARB’s change of
course in recent years to a much more pro-active stance on curbing
super-pollutants.
Our organization worked closely with Senators Lara and Pavley on
the passage of SB 605 (2014), which requires ARB to develop a plan
to reduce emissions of SLCPs no later than January 1, 2016. We
believe the Proposed Strategy is a faithful implementation of that
law, other than the fact that it is several months overdue – which
only emphasizes how important it is to move quickly to put the plan
into action.
The proposed target emission levels are crucial. The urgency of the
climate crisis requires that SLCPs be brought down by substantial
amounts by 2030. We believe the proposed science-based targets for
black carbon, methane, and hydrofluorocarbons are achievable, and
would represent significant progress in the battle against global
warming.
Using a 20-year value for global warming potential is essential. We
agree with the Proposed Strategy’s use of 20-year values for GWP.
Curbing SLCPs quickly offers the opportunity to buy some time while
carbon dioxide emissions are brought down. Time is short to prevent
catastrophic climate change, so a horizon of 20 years – or fewer –
must be the standard.
Restrict Oil and Gas Methane Emissions. ARB should adopt a final
rule this year limiting greenhouse gas emissions from crude oil and
natural gas facilities. These major methane sources have gone too
long without this kind of regulation. ARB, The Division of Oil, Gas
and Geothermal Resources and the other relevant regulatory agencies
should take quick and aggressive action to assure that the
disastrous methane leak at Aliso Canyon is never repeated.
Continue Progress on Reducing Black Carbon. Control measures by ARB
and air districts have succeeded in reducing black carbon by 90
percent over the last 50 years; for the sake of human health and
climate stabilization we must continue this progress, primarily be
reducing particulate matter from diesel exhaust and  wood burning.
This progress will depend on successful implementation of the
proposed Sustainable Freight Action Plan as well as the Mobile
Source Strategy.
Eliminate the Disposal of Organic Waste. We strongly support the
organic waste diversion goals proposed in the SLCP strategy, and we
specifically support the commitment to adopt regulations to phase
out the disposal of organic waste in landfills. The Proposed
Strategy lays out an effective regulatory strategy to prevent the
creation of these inherently avoidable emissions by virtually
eliminating the landfill disposal of organic waste by 2025. We
encourage ARB to continue its close collaboration with CalRecycle,
which testified in favor of the Proposed Strategy. We support the
more detailed comments filed by Californians Against Waste,
including the call for more stringent limits on landfill
emissions.
Regulate Methane Emissions from Dairies. We support the Proposed
Strategy’s call for developing and implementing mandatory
regulations to reduce methane from manure management in the animal
agriculture industry. The agriculture industry has been exempt from
climate standards for too long, and dairies are by far the largest
source of methane emissions in California. It is past time for
dairies to take responsibility for their methane emissions through
enforceable standards.
ARB Should Move Quickly to Implement SLCP Reduction Measures. While
we support SB 1383 (Lara), we also note that ARB already has
authority, under the Global Warming Solutions Act and the
California Clean Air Act, to adopt measures to reduce these super
pollutants. We urge ARB to adopt the Proposed Strategy and move
quickly to implement these measures.

Respectfully,
Bill Magavern
Policy Director
Coalition for Clean Air